Topic:"Cost Recovery" in M12661

1.0 INTRODUCTION - Nova Scotia Power Inc. (NS Power, Company) is applying to the Nova Scotia Energy Board - (NSEB, Board) for approval of the Extra Large Industrial Dispatchable (ELID) Tariff, an above- - the-line (ATL) tariff available to...

AI summary Nova Scotia Power Inc. (NS Power) seeks approval for the Extra Large Industrial Dispatchable (ELID) Tariff to serve Port Hawkesbury Paper LP (PHP), replacing the expiring ELIADC Tariff. The ELID Tariff includes a Dispatchable Rider (DR) to manage PHP's load flexibility, with a Customer Charge for cost recovery. The application references the 2026-2027 General Rate Application (M12451) and its Settlement Agreement.

2.0 TARIFF COMPONENTS Key elements of the ELID Tariff, provided as Attachment 1 to this Application, include the following: • Customer Charge • Demand Charge • Energy Charge • Interruptible Service • Dispatchable Rider • Other Applicable R...

AI summary The ELID Tariff's Customer Charge recovers costs for dispatch services and tariff administration, including tasks like operating procedure development, PHP engagement, and real-time load optimization. The proposed $10,000 monthly charge for 2026-2027 is based on staff and software costs, with future GRA proceedings determining the final rate.

2.2 Demand Charge - In accordance with the Company's Cost of Service Study (COSS), demand-related costs are proposed to be allocated to the ELID Tariff class based on PHP assigned demand at the time of the three coincident peaks (3CP). Rec...

AI summary The document discusses the allocation of demand-related costs to the ELID Tariff class based on PHP's demand during three coincident peaks (3CP), proposing a fixed charge using historical 65 MW data. NS Power disagrees with PHP's argument for using 8 MW, citing the GRA Settlement Agreement and cost-of-service treatment. Proposed 2026/2027 demand charges are $12.872 and $14.310 per kVA/month, respectively.

expected to consume equally across the year, indifferent to changes in the marginal cost of system supply. In light of the size of PHP load, running as a conventional ATL customer risks increasing costs for all ATL customers, including PHP...

AI summary The Dispatchable Rider (DR) aims to align interests of all ATL customers by pricing PHP load on an embedded cost basis, with DR credits fully credited to PHP. Costs are recovered from all ATL customers, ensuring no additional burden on them. The DR leverages existing processes between NS Power and PHP under the ELIADC Tariff, reducing volatility and providing benefits through PHP's system cost contributions.

comparison, the ELIADC Tariff is primarily an incremental DATE FILED: December 29, 2025 Page 15 of 19 The 2026 and 2027 Interruptible Riders, as proposed, adopt the incremental-cost-based LIIR. cost-based tariff. The base cost to supply PH...

AI summary The document discusses the ELIADC Tariff's incremental-cost-based structure, stakeholder concerns about its fairness and complexity, and the proposed ELID Tariff's improvements, including reduced incremental costs, alignment with other tariffs, and simplified pricing. NS Power confirms adequate firm supply for increased service to PHP.

3.2 Financial Benefits to ATL Customers Attachment 2 provides the cost-of-service applicable to PHP using the figures in the SA, including its fuel and non-fuel components and identifies the FCR provided by PHP if served on an ATL tariff f...

AI summary The ELID Tariff increases FCR for ATL customers compared to the ELIADC Tariff, with reductions in 2027 due to PHPW PPA displacing NS Power supply. DR service reduces system costs but benefits PHP, resulting in neutral net effects. Marginal fuel costs impact ATL classes differently based on whether they are above or below average.

EXTRA LARGE INDUSTRIAL DISPATCHABLE TARIFF Page 1 of 8 (25,000 kVA and over) Rate Code X The Extra Large Industrial Dispatchable (ELID) Tariff is an Above-the-Line (ATL) embedded costbased tariff wherein the Company will dispatch the load...

AI summary The ELID Tariff is an ATL embedded cost-based rate structure where NS Power dispatches Port Hawkesbury Paper LP's load to manage demand, reduce costs, and return savings to the customer. Charges are determined via General Rate Applications or regulatory proceedings, with annual year-end calculations under the Dispatchable Rider.

DSM COST RECOVERY RIDER The Demand Side Management Cost Recovery charge (in cents per kilowatt-hour) applicable to the Tariff for the current rate year, shown in the Demand Side Management Cost Recovery Rider, shall apply, in addition to t...

AI summary The Demand Side Management Cost Recovery Rider imposes a charge (in cents per kilowatt-hour) on the Tariff for the current rate year, in addition to the Energy Charge. This charge is part of the regulatory framework for recovering DSM-related costs.

STORM COST RECOVERY RIDER Storm Cost Recovery charges or credits (in cents per kilowatt-hour) applicable to the Tariff for the current rate year, shown in the Storm Cost Recovery Rider, shall apply, in addition to the Energy Charge. (25,00...

AI summary The Storm Cost Recovery Rider introduces additional charges or credits (in cents per kilowatt-hour) applied to the Energy Charge in the Tariff for the current rate year. Rate Code X is specified for customers with 25,000 kVA and over, indicating a tiered structure for storm-related cost recovery.

DISPATCHABLE RIDER TO THE ELID TARIFF (RATE CODE X) Customers taking service under the ELID Tariff will also be subscribed to this Dispatchable Rider (DR). Under this Rider, NS Power will be able to actively manage the Customer's load in a...

AI summary The Dispatchable Rider (DR) under the ELID Tariff allows NS Power to manage customer load via an Operating Procedure, applying Interruptible Rider terms for load above firm contracted levels. Savings from dispatch flexibility are credited to customers annually, calculated by comparing actual system costs to a high load factor baseline scenario.

2026-2027 General Rate Application Settlement Agreement Extra Large Industrial Dispatchable Tariff Application – Attachment 4 Page 10 of 21 GRA Element Settlement Terms Storm Cost Recovery Rider a) The Storm Cost Recovery Rider will be imp...

AI summary The Storm Cost Recovery Rider will be implemented on a pilot basis for 2026 and 2027, with costs during these years eligible for the rider. It will not be implemented permanently as initially proposed, and there is a threshold for making an application to return an amount.

DEMAND SIDE MANAGEMENT COST RECOVERY RIDER (DCRR) The monthly amount computed under each of the rate schedules to which this DSM Cost Recovery Rider is applicable shall be increased or decreased by the DCRR at a class-specific rate per kil...

AI summary The Demand Side Management Cost Recovery Rider (DCRR) adjusts monthly charges under applicable rate schedules using a class-specific rate formula (DCRR = PCR + BA), reflecting cost recovery mechanisms for demand-side management initiatives.

PCR = Program Cost Recovery The PCR includes all estimated costs for the upcoming calendar year for the DSM Plan that has been requested by the Franchise Holder and approved by the NSUAREB (Approved DSM). It includes the cost of planning,...

AI summary The Program Cost Recovery (PCR) encompasses estimated costs for the approved Demand Side Management (DSM) Plan, including planning, implementation, and administrative expenses. It is calculated using Schedule B's cost allocation methodology for each rate schedule.

BA = Balance Adjustment The BA is comprised of two components: - (1) BA1 = Annual Volume Variance Adjustment is calculated for each rate class separately on a previously completed calendar year basis and is used to reconcile the difference...

AI summary The Balance Adjustment (BA) comprises two components: BA1, which reconciles revenue differences using a two-year lag, and BA2, which adjusts for actual DSM program costs post-DSM Term. Both ensure accurate billing based on actual usage and expenditures.

2025 DSM Cost Recovery Rider Charges Effective: January 1, 20265January 1, 2026 The Demand Side Management Cost Recovery Rider (DCRR) charges, along with its components, (PCR) and (BA), for the period from the approved effective date of Ja...

AI summary The 2025 DSM Cost Recovery Rider (DCRR) charges, including Program Cost Recovery (PCR) and Balance Adjustment (BA), apply from January 1, 2025, to December 31, 2025. The BA2 calculation for 2023, based on revenue versus DSM costs, will be applied annually from 2028–2031. The Approved DSM Term refers to the full DSM Plan period (e.g., 2023–2026, 2027–2031).

DSM Cost Allocation MethodApproach There are 3 kinds of cost benefits resulting from DSM: - (1) System avoided future infrastructure and related costs, reduced fuel costs, and contribution to achieving environmental and emissions restricti...

AI summary The text outlines three types of benefits from DSM: system-wide, class-based, and participation-specific. It argues that DSM cost recovery should align with the benefits received by customer classes, with those receiving more benefits bearing higher costs. However, precise allocation is deemed impractical due to DSM program complexities.

Allocation of DSM Program Costs System benefits are allocated to all applicable customer classes in accordance with the Cost of Service Study (COSS) methodology reflecting allocation of generation rate base as per the most recent rate case...

AI summary DSM program costs are allocated using the Cost of Service Study (COSS) methodology, with system benefits distributed to customer classes based on generation rate base allocations. Remaining costs are assigned proportionally to participating classes according to their investment in DSM programs.

Method - Step 1 Allocate the system benefits to all applicable customer classes, as 25% of the total Approved DSM program costs, in accordance with the COSS methodology per the most recent rate case decision. - Step 21 Allocate the class a...

AI summary The method outlines a five-step process for allocating system and class benefits from DSM programs, recovering costs via bundled service rates or direct billing, and annually adjusting allocations based on prior two years' data. It references COSS methodology and BA1/BA2 for true-up adjustments.

Evidence of Colin T. Fitzhenry and Michael P. Gorman Page 11 12 13  NS Power's proposed design of the ELID Tariff and proposed charges and credits are imbalanced and over-charge PHP for its cost of providing service. 14 15 16 17 18  PHP...

AI summary The evidence provided by Colin T. Fitzhenry and Michael P. Gorman critiques NS Power's proposed ELID Tariff design, arguing that it is imbalanced and over-charges PHP. They recommend that the ELID Tariff should include a capacity charge for firm demand service and recover non-firm power supply costs through the energy charge.

- 4 NS Power's proposed design of the ELID does not reasonably reflect the 5 firm and interruptible service provided to PHP under the proposed ELID 6 Tariff. PHP does not support the Company's ELID rate design. If the Board 7 prefers NS Po...

AI summary PHP objects to NS Power's proposed ELID rate design, arguing it does not reflect the actual service provided and results in over-recovery. PHP recommends adjusting the design to reflect NS Power's cost of service and align the tariff with updated energy sales forecasts for accuracy.

15 Q HOW WILL NS POWER PROPOSE TO PASS ON THE BENEFITS OF THE DR AND 16 INTERRUPTIBLE SERVICE TO PHP? 17 A There will be two credits made to PHP cost of service. First, NS Power will provide a 18 billing determinant demand charge credit eq...

AI summary NS Power proposes passing benefits of DR and interruptible service to PHP via two credits: a demand charge credit (matching LIIR interruptible rates plus a 10% premium) and a power supply credit based on modeled savings from dispatching PHP load during high-cost periods. This reduces NS Power's supply costs, benefiting PHP while maintaining costs for ATL customers.

17 Q DOES NS POWER RECOVER PORTIONS OF ITS GENERATING RESOURCE 18 COST THROUGH THE ELID ENERGY CHARGE? 19 A Yes. NS Power uses a System Load Factor ("SLF") methodology to functionally allocate generating resource cost to demand and energy....

AI summary NS Power uses a System Load Factor (SLF) methodology to allocate generating resource costs to demand and energy under the ELID Tariff. This approach applies uniformly to all generation assets, allowing PHP to support cost recovery of a significant portion of generating resource costs through the ELID energy charge.

(2033-2023) NSP PHP Date Hour Demand (kW) Demand (kW) 1/11/2022 1800 2,215,698 70,056 2/15/2022 1900 2,112,013 91,871 12/13/2022 1800 1,973,475 111,230 1/12/2023 900 1,915,457 10,860 2/4/2023 1200 2,467,302 9,219 12/22/2023 1800 2,040,914...

AI summary The table provides peak demand data for NSP and PHP across various dates and hours, with an average demand of 2,120,810 kW for NSP and 65,332 kW for PHP. The data is sourced from the Cost of Service Study (NSUARB M11475).

13 Q WHAT ARE THE RATE IMPLICATIONS FOR PHP IF THE BOARD ACCEPTS YOUR 14 PROPOSED WINTER MONTH SYSTEM COINCIDENT DEMAND FOR PHP? 15 A NS Power provided an updated COSS for 2026 and 2027 based on a reduction in 16 PHP's total demand coincid...

AI summary If the Board accepts PHP's proposed winter demand reduction from 65 MW to 8 MW, PHP's rates would decrease by $6.5M in 2026 and $9.4M in 2027. This aligns with cost causation principles, which NS Power's Application 2 fails to address adequately.

3 TARIFF IN THIS PROCEEDING? 4 A We would recommend that the proposed ELID tariff reflect the current forecast energy 5 sales as provided in PHP's direct evidence. These forecasted energy sales figures 6 more accurately reflect the likely...

AI summary The proposed ELID tariff should align with PHP's forecast energy sales to ensure accurate cost allocations and revenue reflections of PHP's actual service costs. This approach establishes per-unit rates based on total system energy usage, improving financial accuracy.

12 The illustrated increase of 13 percent in 2027 in the simulated PHP revenues, based on 13 PHP's 2025 billing determinants, reflects commensurate increases in the proposed charges 14 under the ELID Tariff which align with the changes in...

AI summary The text discusses the 13% increase in PHP revenues in 2027, aligned with changes in unit system costs from the 2026 and 2027 COSS, and notes that the LIIR Tariff does not incorporate PHP's load, limiting comparability between tables.

NSPI Responses to BW Information Requests 1 Request IR-9: 2 3 Please refer to Exhibit N-1, page 10 lines 5-7 and section 2.5. 4 5 (a) Please identify "the cost of providing DR service" that "is borne by PHP." Is this a 6 reference to the C...

AI summary NSPI responds to BW's information requests regarding the ELID Tariff, addressing dispatch instructions, cost allocation, enforcement mechanisms, and exogenous factors affecting PHP's consumption. Questions focus on cost recovery, dispatchability, and tariff compliance.

PARTIALLY CONFIDENTIAL (Attachment Only) 1 Request IR-2: 2 3 (a) Please provide COSS and resulting tariff reflecting all parameters proposed by PHP 4 in its evidence, including: 5 6 (i) designing the capacity charge to reflect PHP's actual...

AI summary The document outlines a request for the provision of a COSS and resulting tariff that reflects specific parameters proposed by PHP, including adjustments to the capacity charge, interruptible credit, revenue-to-cost ratio, and updated forecast energy requirements for 2026 and 2027. The response refers to a partially confidential attachment containing the requested information.

,476 -6,912 -353 -1,915 -218 -196 -252 -391 -40 -149 -50 (36) (37) TOTAL GEN. FUNCTION 989,064 652,552 33,313 180,772 20,606 18,518 23,804 36,949 3,749 14,078 4,724 (38) (39) TRANSMISSION FUNCTION (40) Transmission - HV (not aplicable as a...

AI summary The text presents a table with various financial and operational metrics, including revenue, expenses, and asset-related figures, associated with different functions and categories. It includes line items such as 'Total Gen. Function,' 'Transmission Function,' and 'Working Capital & Deferred Charges/Credits,' with detailed breakdowns across different sectors and categories. The table appears to be part of a cost-of-service study.

EXHIBIT 3 PAGE 3 OF 5 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL (7) MEDIUM (8) INDUSTRIAL LARGE (9) (10) (11) ELI 2P-RTP MUNICIPAL UNMETERED (12) ALLOCATION FACTOR (36) (...

AI summary This exhibit presents a detailed breakdown of various financial and operational categories, including transmission functions, working capital, and deferred charges. It includes allocation factors and references to specific exhibits and pages, such as E-1B and P-11A, indicating the complexity of the regulatory proceeding.

EXHIBIT 6 PAGE 5 OF 6 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (17) Non-Streetlight-related (18) Streetlight-related $326,443 $7,668 $258,573 $0 $14,489 $0 $36,449 $0 $2,051 $0 $4,421 $0 $4,010 $...

AI summary The document presents a detailed breakdown of costs and revenues, including non-streetlight-related and streetlight-related expenses, operating costs, and non-operating revenue credits. It categorizes these costs by size class and functional areas such as generation and transmission, providing percentages that reflect the relative shares of these costs.

CLASS : GENERAL CLASS : GENERAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fuel Operating Capital Fixed Return Total Total Cost Units Sold Demand Unit Cost Energy Customer Generation (1) Usage (Energy) $332,466 $157,583 $16,45...

AI summary The document presents a detailed breakdown of costs associated with energy generation, transmission, distribution, and retail operations, including fuel, operating, capital, and fixed return costs. It includes unit costs, total costs, and various metrics such as MWh sales and kW demand across different segments of the energy system.

CLASS : SMALL INDUSTRIAL CLASS : SMALL INDUSTRIAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fuel Operating Capital Fixed Return Total Total Cost Units Sold Demand Unit Cost Energy Customer Generation (1) Usage (Energy) $38,15...

AI summary The document presents a detailed cost breakdown for the Small Industrial class in Nova Scotia's regulatory proceeding, including generation, transmission/distribution, and retail costs, along with unit costs and total expenses. The data is sourced from various exhibits and includes breakdowns by energy and demand components.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS FOR THE YEAR ENDING DECEMBER 31, 2026 CLASS : TOTAL COMPANY RATE BASE COSTS (Source Exh 6) Variable Fuel Operating Capital Fixed Return Total Total Cost Units Sold Demand Unit Cost...

AI summary This document presents a detailed rate class disaggregation analysis for Nova Scotia Power Inc. for the year ending December 31, 2026, breaking down costs and revenues by generation, transmission/distribution, and retail segments. It includes various cost components, revenue sources, and unit costs associated with energy delivery and customer services.

EXHIBIT 8B PAGE 1 OF 3 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL (7) MEDIUM (8) LARGE (9) PHP (10) (11) MUNICIPAL UNMETERED (12) ALLOCATION FACTOR (9) SUBST. I...

AI summary The table presents investment and responsibility percentages across various categories, including small, general, and industrial sectors, with allocations and factors indicated for different investment types such as substituted investment, meter investment, and demand-related investments.

REDACTED ELID Tariff CA IR-2 Attachment 1 Page 89 of 94 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Line # AVERAGE RATE BASE RATE BASE 2025 RATE BASE 2026 (462) STEAM AND ASH SALES (463) AMI OPT OUT CHARGE 5,018 831 (464) OTHER REVENUE (46...

AI summary The text presents a table outlining various rate base components and cash working capital (CWC) distribution percentages across different customer categories for 2025 and 2026. The table includes line items such as steam and ash sales, AMI opt-out charges, and revenue and cost details, along with CWC distribution percentages for domestic, general, industrial, and municipal customers.

(20) MAT. & SUPPLIES - OTHER 16,874 8,903 613 3,712 596 435 703 1,143 431 206 132 (21) DEF. CHG Financing 4,646 2,451 169 1,022 164 120 194 315 119 57 36 (22) DEF. CHG Tax 5,142 2,713 187 1,131 182 133 214 348 131 63 40 (23) DEF. CHG Pensi...

AI summary The document presents a detailed breakdown of various financial line items related to Nova Scotia Power Inc., including expenses, financing, tax, pension, and other charges, as well as asset-related adjustments and receivables, with numerical data provided for different years.

EXHIBIT 6 PAGE 1 OF 6 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION (23) CORPORATE TAXES 1,884 1,246 66 342 39 36 41 70 7 27 9 P-14 (24) Non-Operating Revenue: (25) STEAM AND ASH SALES...

AI summary The exhibit presents a detailed breakdown of financial figures, including corporate taxes, non-operating revenue, return on profit/loss, and various adjustments related to demand and allocation. These figures are categorized across different sizes and allocations, with references to specific board orders and direct allocations.

RATE CLASS DISAGGREGATION ANALYSIS BY FUNCTIONAL AREAS CLASS : DOMESTIC RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fixed Costs Demand ($/kW of Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Class monthly N...

AI summary The document presents a detailed breakdown of rate class disaggregation by functional areas, including generation, transmission/distribution, and retail. It includes cost allocations, unit costs, and financial figures related to energy sales, reliability, and customer services, with data sourced from various exhibits and cost files.

CLASS : LARGE GENERAL CLASS : LARGE GENERAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fixed Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Generation (1) Usage (Energy) $53,156 $23,...

AI summary This table details the cost breakdown for a large general class in a regulatory proceeding, including generation, transmission/distribution, and retail costs. It includes fuel, operating, capital, and return costs, as well as unit costs and total costs for various components of the energy system.

(IN THOUSANDS OF DOLLARS) NOVA SCOTIA POWER INC. DETAILED LISTING OF C.O.S.S. INPUT INFORMATION FOR THE YEAR ENDING DECEMBER 31, 2027

AI summary This document presents a detailed listing of Cost of Service (C.O.S.S.) input information for Nova Scotia Power Inc. (NSPI) as of December 31, 2027, including financial data and categories relevant to regulatory proceedings. It outlines input parameters used in determining NSPI's cost structure for regulatory review.

NON-CONFIDENTIAL 1 Request IR-3: 2 3 (a) Please provide a summary table showing allocated costs and rates for PHP and all 4 other ATL classes for 2026 and 2027 in these three scenarios: 5 6 (i) NSPI's proposed ELID Tariff as filed; 7 8 (ii...

AI summary The document outlines a request (IR-3) for a comparison of allocated costs and rates for Port Hawkesbury Paper (PHP) under three tariff scenarios (NSPI's ELID Tariff, PHP's modified ELID, and continued BTL tariff) for 2026-2027. It also asks for quantification of implications on NSPI's PHP deferral account balance, with a response noting a $25.2M and $12.8M cost differential in 2026 and 2027 respectively.

PARTIALLY CONFIDENTIAL 1 The Company provides the following in response to parts (a) and (b) of this IR. 2 3 (a) Confirmed. The 2026-2027 GRA was prepared in accordance with the SA. Changes to this 4 to align with PHP's Evidence will resul...

AI summary NS Power confirms the 2026-2027 GRA aligns with the SA but notes PHP's evidence will cause cost reallocations and price increases. NS Power opposes PHP's proposal to include 8 MW peak demand in capacity cost allocation, citing inconsistency with the GRA settlement agreement. The Board's Decision M12451 avoids re-opening COSS and rate design matters.

NSPI Responses to Industrial Group Information Requests Request IR-5: Reference: N-1, ELID Application, Page 6. Consistent with the foregoing, it is proposed that the assumed costing/billing demand also be adopted and applied for billing p...

AI summary NSPI proposes a fixed charge for demand cost recovery using the PHP 3CP figure for the ELID Tariff class, citing unique service characteristics of a single customer with a large, dispatchable load. This approach diverges from standard practices but claims consistency with ratemaking principles due to challenges in applying conventional ATL cost-of-service methods during system peaks.

REDACTED (Attachment Only) 1 (a) Please refer to the following: 275 41 $21.2 $16.9 $38.1 275 41 $21.2 $17.0 $38.2 0 0 0.0% 0.0% -$0.1 $0.1 $0.1 -0.3% 0.9% 0.2% 468 63 $34.9 $22.1 $57.0 468 63 $34.8 $22.3 $57.0 0 0 0.0% 0.0% -$0.1 $0.2 $0.1...

AI summary The text contains a table with numerical data, including figures related to costs and variances, along with references to regulatory matters such as 'M12451' and 'M12661'. These references point to specific regulatory proceedings or filings, likely related to cost adjustments or rate proposals.

ALLOCATION OF AVERAGE UNDERGROUND WIRE INVESTMENT (1) TOTAL PLANT (2) PRIMARY DEMAND (3) PRIMARY CUSTOMER (4) SECONDARY DEMAND (5) SECONDARY CUSTOMER ( 1) DOMESTIC $53,004 $2,288 $615 $7,451 $42,649 ( 2) SMALL GENERAL 2,967 125 35 414 2,39...

AI summary The document presents a table allocating average underground wire investment costs across different customer classes (domestic, industrial, municipal, etc.) with columns for total plant, primary/secondary demand, and customer categories. Allocation factors (D-2A, C-5, etc.) are applied to distribute costs.

CLASS : ELI 2P-RTP RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fixed Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Generation (1) Usage (Energy) $112,547 $54,979 $5,463 $8,063 $3,950...

AI summary The document presents a detailed breakdown of costs and rate base figures for Generation, Transmission/Distribution, and Retail categories. It includes various line items such as fuel, operating, capital, return, and total costs, along with unit costs and quantities for energy and demand. The data is organized in a table format and provides an overview of financial and operational metrics for a regulatory proceeding.

FOR THE YEAR ENDING DECEMBER 31, 2026 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION (26) NUMBER OF BILLIS (27) % RESPONSIBILITY (28) REVENUE (29) % RESPONSIBILITY (30) % RESPONSIBILITY...

AI summary The document provides a summary of billing and cost allocation percentages for different customer categories for the year ending December 31, 2026, including details on the number of bills, revenue responsibility, and wiring inspection cost allocation factors.

FOR THE YEAR ENDING DECEMBER 31, 2026 (IN THOUSANDS OF DOLLARS) (69) NON-FUNCTIONALIZED (70) GENERAL PROPERTY PLANT 292,481 462,475 287,072 454,929 297,891 470,022 (71) GENERAL PROPERTY PLANT - CWIP 14,812 10,022 19,601 (72) TOTAL GENERAL...

AI summary The document presents financial data for the year ending December 31, 2026, focusing on property plant, working capital, deferred charges, and operating expenses. It includes figures related to total plant in service, working capital components, and deferred charges such as ARO (Asset Retirement Obligation) and COR (Cost of Removal) liabilities.

DETAILED LISTING OF C.O.S.S. INPUT INFORMATION (160) METER DATA SERVICES 440.3 1.6% 638,831 (161) SMART METER OPERATIONS CENTER (SMOC) 1,189.1 4.2% 1,725,124 (162) METER SERVICES - FIELD 1,427.2 5.0% 2,070,655 (163) ELECTRICAL WIRING INSPE...

AI summary The document provides a detailed listing of input information for the Cost of Service Study (C.O.S.S.), including meter data services, smart meter operations, meter services, electrical wiring inspections, and regulatory affairs expenses. The table outlines various costs, percentages, and financial figures for different departments and years.

NOVA SCOTIA POWER INC. 2027 COST OF SERVICE STUDY ANALYSIS R E F E R E N C E G U I D E EXHIBIT COMPARISON OF REVENUE TO EXPENSE RATIOS 1 FUNCTIONALIZATION OF AVERAGE RATE BASE 2 INITIAL CLASSIFICATION OF AVERAGE RATE BASE 2A FINAL CLASSIFI...

AI summary The document presents Nova Scotia Power Inc.'s 2027 Cost of Service Study reference guide, including exhibits analyzing revenue-to-expense ratios, rate base classifications, and operational cost allocations. Key data includes proposed revenue recovery ratios for customer classes in 2026 and 2027, with most classes showing stable or slightly increasing ratios.

(17) Int Credit Amount - PHP 558 (2) (5) (1) INTERR. RIDER DMD ADJ. (3) Dmd. in KWs (4) Int Credit Amount 69,857 11,207 (7) (6) PHP DEMAND ADJUSTMENT CALCULATION (8) Demand Usage Annual Credit Amount Calculation (9) Winter Month kW Coincid...

AI summary The document presents a table detailing an interruptible credit amount calculation, including demand usage, annual credit amount, and priority interruption premium calculations. It includes figures related to kilowatts, kilovolt-amps, and monetary values.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS FOR THE YEAR ENDING DECEMBER 31, 2027

AI summary The document presents a rate class disaggregation analysis for Nova Scotia Power Inc. for the year ending December 31, 2027, focusing on financial and regulatory aspects of utility operations.

CLASS : GENERAL CLASS : GENERAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fixed Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Generation (1) Usage (Energy) $324,155 $142,095 $16,17...

AI summary The text presents a detailed breakdown of costs associated with generation, transmission, distribution, and retail operations, including fuel, operating, capital, and return costs. It outlines unit costs, total costs, and various metrics such as MWh sales and energy requirements.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS FOR THE YEAR ENDING DECEMBER 31, 2027 CLASS : MEDIUM INDUSTRIAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fuel Operating Capital Fixed Return Total Total Cost Units So...

AI summary This document presents a detailed rate class disaggregation analysis for Nova Scotia Power Inc. for the year ending December 31, 2027, breaking down costs and revenues by different classes, including generation, transmission/distribution, and retail. It includes various cost components such as fuel, operating, capital, and fixed return, as well as unit costs and total revenues.

FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) (1) TOTAL (2) TOTAL (3) UNIT COST (4) TOTAL (5) (6) (7) VARIANCE CALC (284) RETAIL (285) NON-FUNCTIONALIZED (286) GENERAL PROPERTY 6,242.3 42,846.9 67,943.7 0.0 0.0 0 6,242 42...

AI summary The document presents financial data for the year ending December 31, 2027, including various line items such as retail, non-functionalized, and general property costs, interest charges, preferred dividends, corporate taxes, and retained earnings. The data includes unit costs, totals, and variance calculations.

EXHIBIT 6 PAGE 6 OF 6 (2) (5) (7) (1) INTERR. RIDER DMD ADJ. (3) Peak Dmd. in KWs (at Generator) (4) Int Credit Amount (6) PHP DEMAND ADJUSTMENT CALCULATION 69,594 11,165 (8) Demand Usage Annual Credit Amount Calculation (9) (10) Winter Mo...

AI summary The document presents a table with various demand adjustment calculations, including peak demand, credit amounts, and power factor adjustments. It includes values related to winter month demand, kilovolt-amps (kVA), and associated financial figures. The table also references priority interruption demand adjustments and associated credit amounts.

DEVELOPMENT OF ALLOCATION FACTORS (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION (5) SUBST.,POLE&WIRE-DMD. (6) % RESPONSIBILITY $393,210 100.00% $262,605 66.78% $14,368 3.65% $76,610 19...

AI summary The text presents a table detailing the development of allocation factors for various categories, including responsibility percentages and financial figures. It outlines the distribution of costs across different classifications such as small, general, medium, and large, with corresponding percentages and allocation codes (e.g., P-3, P-4, P-5).

DEMAND CLASSIFICATION (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (9) (10) (11) ALLOCATION (30) Streetlights: (31) OPERATING & MAINT. 831 0 0 0 0 0 0 0 0 0 831 EXH 6A (32) GRANTS IN LIEU OF TAXES 317 0 0 0 0...

AI summary The document provides a detailed breakdown of demand classification, including operating and maintenance costs, grants, depreciation, interest, taxes, and returns, with allocations categorized by size and type. It includes specific figures and references to exhibits and pages for each category.

FOR MARCH 2027 (1) MWH (2) ENERGY LINE (3) ENERGY (4) CLASS NON- COINCIDENT (5) SYSTEM COINCIDENT (6) SYSTEM COINCIDENT (7) DEMAND LINE (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT (12) SHORE POWER (13) GEN.REPL./LOAD FOLL. (14) ELIADC (15)...

AI summary The table presents data for March 2027, including energy line items, system coincident demand, and export sales. It shows various categories such as Shore Power, GEN.REPL./LOAD FOLL., ELIADC, and others, with corresponding values and percentages. The data includes sub-totals and total figures for energy and demand lines.

CLASS : LARGE GENERAL CLASS : LARGE GENERAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fuel Operating Capital Fixed Return Total Total Cost Units Sold Demand Unit Cost Energy Customer Generation (1) Usage (Energy) $52,109 $25,...

AI summary The document presents a detailed cost breakdown for a large general class, including generation, transmission/distribution, and retail costs. It includes figures for variable fuel, operating, capital, and fixed return costs, along with unit costs and total costs for energy and demand.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS FOR THE YEAR ENDING DECEMBER 31, 2026 CLASS : MEDIUM INDUSTRIAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fuel Operating Capital Fixed Return Total Total Cost Units So...

AI summary This document presents a rate class disaggregation analysis for Nova Scotia Power Inc. for the year ending December 31, 2026, detailing costs and revenue across various classes, including generation, transmission/distribution, and retail, with breakdowns of variable fuel, operating, capital, and fixed return costs.

NOVA SCOTIA FUNCTIONALIZATION OF FOR THE YEAR ENDING (IN THOUSANDS (1) REGULATORY AFFAIRS (2) Advocacy Expense 0.1 (0) 3 3 0 1 8 55 1 70 (3) Other Expenses 0.2 (1) 12 11 0 2 32 216 4 277 (4) Subtotal 0.3 (1) 15 14 0 3 40 271 6 347 (5) (6)...

AI summary The document presents a functionalization report detailing various expenses categorized under different departments such as Regulatory Affairs, Finance Group, Enterprise Services, and Human Resources. The report outlines specific line items and totals for the year ending, providing a breakdown of costs incurred across different functions.

FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) (1) TOTAL COMPANY (2) DOMESTIC (3) SMALL GENERAL (4) GENERAL (5) GENERAL LARGE (6) SMALL (7) MEDIUM INDUSTRIAL INDUSTRIAL INDUSTRIAL (8) LARGE (9) ELI 2P-RTP (10) (11) MUNICIP...

AI summary The document presents financial data for the year ending December 31, 2027, including purchases from wind energy sources, imports, and operational and maintenance costs for steam and hydro facilities. The data is categorized by different customer segments and includes allocations and factors for various line items.

EXHIBIT 6 PAGE 4 OF 6 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION (12) Subtotal (13) Non-Operating Revenue Credit (14) Subtotal $159,437 ($317) $159,120 $105,402 ($210) $105,193 $5,5...

AI summary The text presents a table with various financial figures, including revenue credits, subtotals, and distribution costs categorized by different segments such as small, general, medium, and large. It also includes non-operating revenue credits and operating costs for retail and other segments.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS CLASS : SMALL GENERAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fuel Operating Capital Fixed Return Total Total Cost Units Sold Demand Unit Cost Energy Customer Genera...

AI summary The document presents a detailed rate class disaggregation analysis for Nova Scotia Power Inc., breaking down costs and revenues across various categories including generation, transmission/distribution, and retail. It includes figures for rate base, variable fuel costs, operating expenses, capital, fixed return, and unit costs.

NOVA SCOTIA POWER INC. DEVELOPMENT OF ALLOCATION FACTORS (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL ELI 2P-RT...

AI summary The document presents a table outlining the development of allocation factors for Nova Scotia Power Inc., detailing various expense and revenue categories with percentages of responsibility distributed among different customer segments and industrial classifications.

REVENUE TO EXPENSE COMPARISON (1) TOTAL DMD.RELATED (2) TOTAL ENG.RELATED (3) UNIT COST ENG.RELATED (4) TOTAL CUST.RELATED (5) TOTAL OPER. (6) TOTAL RATE (7) % REVENUE VARIANCE CALC (298) Power Factor Adjustment (299) LIR Credit ($/kVA) (3...

AI summary The text presents a revenue-to-expense comparison table, including categories such as Power Factor Adjustment, LIR Credit, and various customer solutions allocators. It outlines percentages and allocations for different types of customers and operations, with some variance calculations included.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS CLASS : LARGE GENERAL RATE BASE (Source Exh. 3) Variable Fixed COSTS (Source Exh 6) Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Genera...

AI summary The document presents a detailed breakdown of Nova Scotia Power's rate class disaggregation analysis, including various cost components such as fuel, operating, capital, and return on investment, along with unit costs and total costs for different segments like generation, transmission/distribution, and retail.

NOVA SCOTIA POWER INC. (1) TOTAL COMPANY (2) DOMESTIC (3) SMALL GENERAL (4) GENERAL (5) GENERAL LARGE (6) SMALL (7) MEDIUM INDUSTRIAL INDUSTRIAL INDUSTRIAL (8) LARGE (9) ELI 2P-RTP (10) (11) MUNICIPAL UNMETERED (12) ALLOCATION FACTOR (18)...

AI summary The document presents a detailed financial breakdown for Nova Scotia Power Inc., including various expense and revenue categories such as advocacy expenses, depreciation, interest, taxes, and non-operating revenue. Specific line items and allocations are provided across different customer segments and business areas.

CLASS : UNMETERED CLASS : UNMETERED RATE BASE COSTS (Source Exh 6) Variable Fixed Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Generation (1) Usage (Energy) $11,569 $5,067 $567 $868 $402 $1,837...

AI summary This document presents a detailed cost breakdown for the 'Unmetered' class in a Nova Scotia regulatory proceeding, including generation, transmission/distribution, and retail costs. It includes various line items such as fuel, operating, capital, and return costs, along with unit costs and total costs. The data provides insight into the financial structure and cost distribution for this specific class.

CLASS : MEDIUM INDUSTRIAL CLASS : MEDIUM INDUSTRIAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fixed Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Generation (1) Usage (Energy) $63,...

AI summary The document presents a detailed breakdown of costs and revenue for the Medium Industrial class in Nova Scotia's regulatory proceeding, including generation, transmission/distribution, and retail costs, along with unit costs and total revenue.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS FOR THE YEAR ENDING DECEMBER 31, 2026 CLASS : TOTAL COMPANY RATE BASE Variable Fixed COSTS (Source Exh 6) Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand...

AI summary This document presents Nova Scotia Power Inc.'s rate class disaggregation analysis for the year ending December 31, 2026. It includes detailed breakdowns of costs across various categories such as generation, transmission/distribution, and retail, with data on fuel, operating, capital, and return costs, as well as unit costs and total costs.

DEVELOPMENT OF ALLOCATION FACTORS FOR THE YEAR ENDING DECEMBER 31, 2027 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION (37) TOT. EXP DMD. ( DIST.) $140,786 $92,707 $5,057 $25,531 $1,681...

AI summary The document outlines the development of allocation factors for the year ending December 31, 2027. It includes tables with various expense categories, percentages of responsibility, and allocation factors for different segments such as small, medium, and large.

73 (21) DEF. CHG Financing 4,488 2,961 151 820 94 84 108 168 17 64 21 (22) DEF. CHG Tax 4,825 3,183 163 882 101 90 116 180 18 69 23 (23) DEF. CHG Pension 34,205 22,567 1,152 6,252 713 640 823 1,278 130 487 163 (24) DEF. CHG Steam Assets 0...

AI summary The text presents a detailed financial breakdown of various line items under the 'DEF. CHG' and 'DEF. CR' categories, including financing, tax, pension, fuel deferral, and other costs, as well as asset retirement obligations (ARO) for steam, hydro, wind, and other resources. It also includes a subtotal and total general function figures.

CLASS : SMALL INDUSTRIAL CLASS : SMALL INDUSTRIAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fixed Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Generation (1) Usage (Energy) $38,82...

AI summary This table presents a detailed breakdown of costs and rates for the Small Industrial class in Nova Scotia, including generation, transmission/distribution, and retail costs, along with unit costs and total expenses.

CLASS : MUNICIPAL CLASS : MUNICIPAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fuel Operating Capital Fixed Return Total Total Cost Units Sold Demand Unit Cost Energy Customer Generation (1) Usage (Energy) $18,365 $7,889 $906...

AI summary The document presents a detailed breakdown of costs and revenue for a municipal class, including generation, transmission/distribution, and retail segments. It outlines various cost categories such as variable fuel, operating, capital, and fixed return, along with unit costs and total expenses. The data provides insights into the financial structure of the utility services.

REVENUE TO EXPENSE COMPARISON (1) TOTAL DMD.RELATED (2) TOTAL ENG.RELATED (3) UNIT COST ENG.RELATED (4) TOTAL CUST.RELATED (5) TOTAL OPER. (6) TOTAL RATE (7) % REVENUE VARIANCE CALC (295) Normal Interruption Cost (296) Interr. Rider Coinci...

AI summary The document presents a revenue to expense comparison, focusing on various cost-related categories such as normal interruption costs, power factor adjustments, and customer solutions allocators, with percentages and figures indicating allocations and variances across different sectors and customer types.

NOVA SCOTIA POWER INC. ALLOCATION OF CUSTOMER SERVICE FIELD EXPENSES (1) TOTAL COMPANY (2) METER READING (4) WIRING INSPECTION ( 1) DOMESTIC $7,448 $2,002 $5,445 ( 2) SMALL GENERAL 946 135 811 ( 3) GENERAL 839 160 680 ( 4) GENERAL LARGE 35...

AI summary The document presents a table detailing the allocation of customer service field expenses across different customer categories for Nova Scotia Power Inc., including domestic, small general, general, industrial, and others, with specific allocations for meter reading and wiring inspection expenses.

CLASS : LARGE INDUSTRIAL CLASS : LARGE INDUSTRIAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fixed Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Generation (1) Usage (Energy) $101,8...

AI summary The document presents a detailed breakdown of costs and rate base information for the Large Industrial class, including fuel, operating, capital, and return costs for generation and transmission/distribution. It includes unit costs, energy requirements, and demand metrics.

NOVA SCOTIA POWER INC. SUMMARY OF SYSTEM ENERGY LINE LOSSES FOR THE YEAR ENDING DECEMBER 31, 2026

AI summary This document provides a summary of system energy line losses for Nova Scotia Power Inc. for the year ending December 31, 2026. It outlines the methodology used to calculate these losses and their impact on operational efficiency and cost recovery.

FOR THE YEAR ENDING DECEMBER 31, 2027 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION (7) CASH - OTHER (CWC allocation) 100.0% 73.77% 5.21% 12.06% 1.38% 1.51% 2.54% 2.53% 0.00% 0.48% 0.5...

AI summary The document presents a detailed breakdown of various financial allocations and responsibilities across different categories for the year ending December 31, 2027. It includes percentages and monetary values for cash allocation, customer revenue, advocacy expenses, late payment charges, connection charges, and NSF responsibilities.

NON-CONFIDENTIAL (d) Please confirm that ELID load is expected to operate at an approximate 20% load factor by 2027 (160 MW peak, per N-1 page 5, and 304 GWh per page 3). If not, please indicate the assumed customer-specific annual load fa...

AI summary The response confirms that ELID load is expected to operate at a 20% load factor by 2027, with assumptions based on the Cost of Service Study (COSS) and the Dispatchable Rider (DR) credit. The DR credit is intended to shift demand to lower-cost hours, similar to the ELIADC Tariff, and reduce the impact of PHP's energy consumption on economic patterns as more wind generation is added.

1 Request IR-9: 2 3 NSPI states at page 7 that the ultimate energy charge is subject to change based on the - 4 outcome of the ongoing Court proceedings regarding FLG2 responsibility. Please provide - 5 an analysis quantifying the impact o...

AI summary NSPI requests an analysis of the impact on Large Industrial and Medium Industrial customers if PHP is not found responsible for FLG2 costs, with a reallocation of those costs. NS Power provides a forecast assessment including FLG2-related costs and references Table 1 for the impact analysis.

Background – Justifications & Cost Allocation for Priority Interruptibility

AI summary This section provides background on the justifications and cost allocation for priority interruptibility, focusing on the rationale behind the allocation of costs associated with this mechanism.

NSPI Responses to Industrial Group Information Requests 1 Request IR-16: 2 3 Reference: N-1, ELID Application, page 11. 4 5 6 7 8 9 10 11 12 13 Based on initial analysis completed in 2025 utilizing forecast data, the Company has estimated...

AI summary NSPI estimates that optimal load dispatch under the ELIADC Tariff could save PHP $7 to $11 million annually, but actual savings are expected to be about half due to operational constraints. The Industrial Group requests specific examples from ELIADC operations to compare with ADC values.

NON-CONFIDENTIAL 1 (iii) The PHP proposal is accepted, and the ELID interruptibility credit is 2 established based on a higher benchmark avoided cost, but the LIIR credit is 3 retained to be based on a different factual assumption about th...

AI summary The document discusses the acceptance of the PHP proposal and the establishment of the ELID interruptibility credit based on a higher benchmark avoided cost, while retaining the LIIR credit based on a different assumption. NS Power explains that the LIIR credit is not outdated and will be reviewed in the next GRA. The response also mentions the deferral of revenue shortfall and its potential recovery from all above-the-line customers.

NSPI Responses to NSEB Information Requests 1 Request IR-1: 6 consideration of implications of holding PHP load and the loads of other 7 interruptible customers as Operating Reserve. 8 9 • Examination and quantification of benefits, if any...

AI summary NSPI is responding to NSEB information requests regarding the implications of holding PHP load and other interruptible customers' loads as Operating Reserve, including reliability benefits, cost of service treatment, and system benefits associated with dispatch of PHP load.

NSPI Responses to NSEB Information Requests 1 cost to serve the NS Power dispatched PHP load. (i.e. the credit for DR will equal the 2 benefit of DR, returning the FAM to the same result as if PHP had run flat without DR.) 3 4 (c) Per the...

AI summary NSPI responds to NSEB information requests regarding the cost of serving PHP load, the allocation of savings from demand response, and concerns about the proposed ATL tariff. NSPI explains that under the ELIADC Tariff, PHP would accrue full benefits from dispatching load, and highlights concerns about the ATL tariff's impact on PHP.

NSPI Responses to Port Hawkesbury Paper Information Requests 1 Request IR-1: 2 3 Reference: Application, page 5, lines 15-17. 4 5 "In accordance with the Company's Cost of Service Study (COSS), demand 6 7 related costs are proposed to be a...

AI summary NSPI responds to information requests related to the allocation of demand-related costs to the ELID Tariff class based on PHP assigned demand at the time of three coincident peaks (3CP), and the unavailability of data on hourly Net Load breakdown by customer class due to a cyber incident.

NSPI Responses to SBA Information Requests 1 Request IR-1: 2 3 Refer to M12661, Exhibit N-1, the Application for Approval of an Above-the-Line Tariff 4 applicable to Port Hawkesbury Paper (the "Application"), Section 2.2 Demand Charge, 5 s...

AI summary NSPI is responding to SBA information requests regarding the Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper. The request includes questions about demand charge rationale, definitions, historical 3CP data, and billing practices.

NON-CONFIDENTIAL 1 Request IR-7: 2 3 Refer to M12661, Exhibit N-1, the Application submitted by NS Power, Attachment 3, page 4 1 of 1, please answer the following: 5 6 (a) Please provide the supporting workpapers with intact formulas for t...

AI summary This regulatory proceeding document contains a request (IR-7) and response related to cost estimates, customer charges, and reporting practices by NS Power. The request includes inquiries about supporting workpapers, cost inclusion, and annual reporting, with responses referring to prior submissions and confirming certain practices.

NSPI Responses to Synapse Energy Economics, Inc. Information Requests 1 Request IR-1: 8 • provision of supplemental service by own or a third-party generation (GRLF, Shore 9 Power, RtR Energy Balancing and Standby Service Tariffs); 10 11 •...

AI summary The text discusses NSPI's responses to Synapse Energy Economics' information requests, including specific service requirements and tariff structures that affect the availability of Alternative Ancillary Rate (AAR) options for large customers. It also references the Board's decision on a Generic Rate Design Hearing and requests for NS Power's cost of service study related to PHP.

NSPI Responses to Synapse Energy Economics, Inc. Information Requests 1 Request IR-7: 8 (b) Is this treatment differen than the LI tariff or interruptible tariff? Please explain. 9 10 Response IR-10: 11 12 (a) NS Power allocates demand-rel...

AI summary NSPI explains how demand-related costs of generation and transmission are allocated to rate classes using the 3CP method, noting that interruptible loads are both credited and charged for these costs. The response also clarifies that the treatment of interruptible service is not different from the LI tariff or interruptible tariff.

PARTIALLY CONFIDENTIAL (Attachment Only) 1 Request IR-30: 2 3 Refer to the Direct Evidence of Fitzhenry and Gorman, p. 19. 4 5 (a) Please provide all confidential responses to Undertaking U-3 in NSEB M12451. 6 7 (b) Please also provide the...

AI summary The text references a request (IR-30) for confidential responses to an undertaking and the provision of a confidential version of the Cost of Service Study (COSS). It also mentions the 2026-2027 General Rate Application (M12451) and references the Board's recent decision in that matter.

EXHIBIT 6 PAGE 5 OF 6 (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) TOTAL COMPANY DOMESTIC SMALL GENERAL GENERAL GENERAL SMALL MEDIUM LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL LARGE PHP MUNICIPAL UNMETERED (1) COSTS BY FUNCTIONAL AREAS (2) Ge...

AI summary The table presents a detailed breakdown of costs by functional areas and customer segments for Nova Scotia Power, including FAM-related and non-FAM-related costs, transmission operating costs, and revenue credits. It covers various categories such as generation, transmission, and subtotal costs for different customer types.

CLASS : GENERAL CLASS : GENERAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fuel Operating Capital Fixed Return Total Total Cost Units Sold Demand Unit Cost Energy Customer Generation (1) Usage (Energy) $332,904 $158,757 $16,49...

AI summary The document provides a detailed breakdown of costs associated with energy generation, transmission, distribution, and retail in a Nova Scotia regulatory proceeding. It includes figures for variable fuel costs, operating expenses, capital expenditures, and unit costs per kW.h, as well as total costs and revenue requirements.

REDACTED ELID Tariff Synapse IR-30 Attachment 1 Page 96 of 96 REDACTED (CONFIDENTIAL INFORMATION REMOVED)

AI summary The document is a redacted attachment from a Nova Scotia regulatory proceeding related to the ELID Tariff and Synapse IR-30. It is part of a 96-page submission, with confidential information removed. The content likely pertains to rate design, cost recovery, or tariff structures for industrial energy services.

REDACTED ELID Tariff Synapse IR-30 Attachment 3 Page 29 of 95 REDACTED (CONFIDENTIAL INFORMATION REMOVED) NOVA SCOTIA POWER FUNCTIONALIZATION OF OPERA FOR THE YEAR ENDING DECEM (IN THOUSANDS OF DOL

AI summary The document is a redacted portion of a Nova Scotia Power functionalization of operations report for the year ending December, presented in thousands of dollars. Key details are omitted due to confidentiality.

NOVA SCOTIA POWER INC. ALLOCATION OF OPERATING EXPENSES FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (22) PREFERRED DIVIDENDS 0 0 0 0 0 0 0 0 0 0 0 P-14 (23) CORPORATE T...

AI summary The document provides a detailed breakdown of Nova Scotia Power Inc.'s allocation of operating expenses for the year ending December 31, 2027, including corporate taxes, preferred dividends, and various revenue and adjustment items such as interruptible rider demand adjustments and ELI 2P-RTP demand adjustments.

FOR THE YEAR ENDING DECEMBER 31, 2027 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION (26) NUMBER OF BILLIS (27) % RESPONSIBILITY (28) REVENUE 472,080 100.00% 776,974 0.00% 42.17% 199,09...

AI summary The document presents a detailed breakdown of billing numbers, revenue, and cost allocation percentages for different customer categories in Nova Scotia for the year ending December 31, 2027. It includes distribution of responsibility and wiring inspection cost allocation across various segments.

NOVA SCOTIA POWER INC. DETAILED LISTING OF C.O.S.S. INPUT INFORMATION FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) (207) (293) CORPORATE TAXES (294) RETAINED EARNINGS 11,008 212,356 Allowance for Funds Net (17,343) 154,0...

AI summary The document presents a detailed listing of input information for Nova Scotia Power Inc.'s Cost of Service Study (COSS) for the year ending December 31, 2027, including various financial and operational data points such as taxes, retained earnings, interruption costs, and customer solutions allocators.

REDACTED ELID Tariff Synapse IR-30 Attachment 4 Page 2 of 15 # iuel Co st of Se ervice Al locatio n of Fue el Expen ses am ong Rate e Classes FOR THE YEAR ENDING I DECEMBER 31, 2027 COLUMN 0 P Q R s Т U V w x Y Z AA AB Fuel- related C o st...

AI summary This table presents the allocation of fuel expenses among rate classes for the year ending December 31, 2027, including breakdowns of fixed energy-related and demand-related costs, total fuel-related costs, and other associated expenses and revenues.

Rate Class recovered in fuels Foreign Exchange Total Fuel-related costs Adjusted for R/C ratio and Unbalanced Relative Share Adjusted for R/C ratio and Balanced cents per kWh

AI summary The table outlines various rate classes and associated fuel-related costs, including adjusted figures based on the R/C ratio and balanced/unbalanced factors, with costs expressed in cents per kWh. It appears to be part of a cost-of-service study or tariff-related analysis.

REDACTED ELID Tariff Synapse IR-30 Attachment 4 Page 12 of 15 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Jan-27 Feb-27 Mar-27 Apr-27 May-27 Jun-27 Jul-27 Aug-27 Sep-27 Oct-27 Nov-27 Dec-27 Annual $57,665,346 $47,414,297 $37,738,955 $19,94...

AI summary The document presents financial data related to power purchases and costs over a multi-year period, including figures for purchased power from biomass and wind sources, as well as a supplementary block cost. These figures are likely part of a regulatory proceeding related to tariff structures and cost recovery.

Request IR-1: In their evidence, Brubaker & Associates state: The interruption demand service will not impose resource capacity cost on NS Power because this demand will be served only on an as-available basis. Hence, NS Power can avoid in...

AI summary Brubaker & Associates argue that interruptible demand service will not require capacity charges for NS Power as it is served on an as-available basis, avoiding resource capacity costs. Costs will be recovered via the ELID energy charge, which covers fuel/energy and non-fuel service costs, without requiring an interruptible credit above PHP's 8 MW firm demand.

1 Response IR-1: - (a) If the Board adopts an 8 MW demand allocator, the resulting rates will only reflect the costs of providing firm service. In this scenario, because PHP is not being charged for the system capacity required to serve it...

AI summary The response discusses the implications of adopting an 8 MW demand allocator on rates and interruptible credits for PHP, contrasting scenarios where the allocator exceeds 8 MW. It also rejects the proposed ELID tariff, citing inconsistencies with PHP's position on cost causation and credit pricing. The analysis centers on tariff design, demand-side management, and cost recovery mechanisms.

Response IR-3: PHP's primary position is that the 3-CP demand allocator should be set at 8 MW to reflect only its firm demand, as interruptible load does not drive system capacity investment costs. Including the 57 MW of interruptible dema...

AI summary PHP argues the 3-CP demand allocator should be set at 8 MW to reflect only firm demand, excluding interruptible load. It proposes a $13.107/KVA interruptible credit as a secondary alternative if the 8 MW allocator is rejected, ensuring economic neutrality for firm customers regarding NS Power's generation investment decisions.

siders any aspect of PHP's proposed position as set out in PHP's evidence (whether as indicated above or otherwise) to be inconsistent with any terms of the 2026-2027 GRA settlement agreement and why. In answering this question, and withou...

AI summary PHP's proposed position is questioned regarding consistency with the 2026-2027 GRA settlement agreement, focusing on load forecast updates affecting cost allocation and rate design, and inclusion of 8 MW peak demand in NS Power's capacity cost allocation. The inquiry seeks clarification on alignment with the agreement and potential need to re-open related matters.

1 Request IR-3: 2 3 Reference: N-2, Evidence of C. Fitzhenry and M. Gorman, page 3. 4 5 Preamble: PHP's consultant, Brubaker & Associates, Inc., states that the current ELID R/C 6 ratio is 1.04373 and recommends an R/C ratio of 1.0 "ensuri...

AI summary PHP argues that a new ATL tariff class should start with an R/C ratio of 1.0 to avoid cross-subsidies and ensure competitive neutrality, citing the Principle of Cost-Causality. It distinguishes this from past cases where gradualism was applied to protect existing classes.

Response IR-8: - (a) See Attachment IG IR-8(a). The monthly energy demand is developed as part of the internal annual budget process that is proprietary to PHP and is based on projected monthly paper order fulfillment and the energy requir...

AI summary PHP's energy demand projections for 2026 are based on internal budgeting and wind generation forecasts, with a 4.5% variance in production estimates. The company argues that higher energy costs from wind projects could exceed allocated costs if the project isn't operational, and their financial responsibility is limited to the ELID tariff and PPA.

Response IR-2: Although PHP understands it would meet the availability requirements to take service under the Large Industrial Rate Interruptible Rider tariff, this tariff was not designed to accommodate the dispatch service proposed to be...

AI summary PHP argues the Large Industrial Rate Interruptible Rider tariff is unsuitable for its dispatch service and requires separate cost allocation. NS Power proposes treating PHP as a distinct rate class due to unique load characteristics. PHP suggests a below-the-line tariff if an above-the-line option is unavailable.

lication for the PHP successor tariff" and that "…the creation of the proposed deferral account, and the assumptions underlying it, do provide some certainty for the utility and the customer classes." - (b) The GRA Settlement Agreement neg...

AI summary The GRA Settlement Agreement established a revenue-to-cost ratio for PHP, allowing parties to take positions on the PHP tariff process. A deferral account was proposed to address revenue variances between Board decisions and GRA assumptions. The Board retains authority over cost recovery, as emphasized by NS Power in M12451.

Request IR-2: 1 2 3 Reference: Evidence of Colin T. Fitzhenry and Michael P. Gorman (BAI), page 19. NS Power provided an updated COSS for 2026 and 2027 based on a reduction in PHP's total demand coincident with the winter system peaks redu...

AI summary NS Power provided an updated COSS for 2026 and 2027, leading to a reduction in PHP's rate by approximately $6.5 million in 2026 and $9.4 million in 2027 due to decreased winter system demand from 65 MW to 8 MW in Undertaking U-3.

Request: Please confirm, or explain otherwise, that the reduction in cost allocation to PHP created by the reduction in PHP demand from 65 MW to 8 MW by service area as apportioned to PHP in the 2026 and 2027 Cost of Service Studies and as...

AI summary The request seeks confirmation or explanation regarding the reallocation of cost reductions from PHP due to decreased demand, specifically whether these reductions would be apportioned to other above-the-line rate classes in the 2026 and 2027 Cost of Service Studies.

M14251 CA IR- 001 (65 MW Demand) M12451 U-3 (8 MW Demand) Var. ($) Var. (%) M14251 CA IR- 001 (65 MW Demand ) M12451 U-3 (8 MW Demand) Var. ($) Var. (%)

AI summary The text presents a table with matter numbers (M14251 and M12451) and associated details, including demand values and variations in dollars and percentages. It appears to be related to a cost-of-service study, likely involving Nova Scotia Power Incorporated (NSP) and Port Hawkesbury Paper LP (PHP).

e ability to serve PHP expected load according to its dispatch. PHP also notes the response to NSP IR-3 (b) which PHP has notified NS Power of its drop in maximum expected load from the previous year. Request IR-5: Reference: Direct Eviden...

AI summary PHP raises concerns about the ELID tariff, noting its drop in expected load and uncertainty about tariff differences. It requests clarification on ATL vs. BTL tariff distinctions, particularly regarding fuel and non-fuel components. PHP acknowledges the ELID tariff's fuel component but emphasizes BTL alternatives may include embedded non-fuel costs, though it cannot confirm this distinction definitively.

(b) Under the proposed ELID Tariff, PHP's understanding is that the Company proposes to credit PHP for the continued provision of Priority Interruptible service at a value of 10% of the Interruptible Credit, which is approximately $500,000...

AI summary The proposed ELID Tariff would credit PHP for providing Priority Interruptible service at 10% of the Interruptible Credit, approximately $500,000. NS Power argues that the ELID Energy Charge recovers both fuel and non-fuel costs of serving interruptible demand, and thus no additional interruptible credit is needed beyond PHP's firm demand of 8 MW.

Response IR-7: - (a) PHP cannot confirm that non-fuel energy charges consist strictly of energy-related fixed costs. Based on the System Load Factor ("SLF") methodology, generating resource costs are functionally allocated to both demand a...

AI summary PHP argues that non-fuel energy charges recover production capacity costs via the ELID energy charge, while NS Power clarifies that energy rates capture non-fuel expenses. The ELID Tariff's interruptible credit aligns with LIIR terms but differs from NS Power's standard practice. BAI questions if the ELID Tariff's demand charge and interruptible credit match their proposal, with NS Power noting discrepancies in capacity cost calculations.

Response IR-9: - (a) Confirmed that the Dispatchable Rider is designed to credit estimated system energy cost savings specifically to PHP. However, BAI cannot confirm that these savings accrue solely to PHP. While the credit is intended to...

AI summary PHP argues the Dispatchable Rider unfairly allocates benefits from load flexibility, while BAI and NS Power disagree on interruptible credit methodologies. BAI asserts transmission costs should not be assigned to PHP's load if it doesn't drive system peaks, aligning with cost-causation principles. Disputes center on credit design, cost allocation, and methodology fairness.

Response IR-5: (a) The Electric Utility Cost Allocation Manual, January 1992, (NARUC Manual). The NARUC Manual doesn't use the term interruptible, but it does recognize the concept of shifting demands on the system to avoid generation capa...

AI summary The NARUC Manual (1992) discusses cost allocation principles, emphasizing shifting demand to avoid generation capacity costs and attributing costs to customers causing them. It highlights the utility's flexibility in matching supply with demand using base load facilities and the regulatory purpose of cost allocation to fairly assign costs based on customer impact.

Request IR-6: Refer to M12661, Exhibit N-2, Evidence of Colin T. Fitzhenry and Michael G. Gorman on behalf of PHP, regarding the non-fuel savings created by the Dispatchable Rider ("DR"), please answer the following: a) Does PHP believe th...

AI summary The document requests PHP's position on the Dispatchable Rider (DR) component, including its inclusion of avoided transmission and production costs, potential overlap with interruptible credit, and whether DR benefits are fully passed to PHP, along with a table of credit attributes.

Response IR-8: (a) The referenced NS Power study is based on BAI's understanding of how these studies are conducted for NS Power's system. (b) PHP is unaware of any high-voltage system upgrades that would be triggered when PHP's winter coi...

AI summary NS Power's study relies on BAI's methodology. PHP states no high-voltage upgrades would be triggered by its winter peak contributions and requests a pricing model reflecting NS Power's costs, including a demand charge with an interruptible credit for excess demand beyond 8 MW.

Response IR-1: - The Cost of Service GRA element in the Settlement Agreement is as follows: - a) The COS as set out in the Draft GRA will be included in the 2026-2027 GRA and put forward for approval, subject to the following: (a) use of t...

AI summary The Settlement Agreement outlines the Cost of Service (COS) GRA element for 2026-2027, subject to future proceedings on methodology and cost apportionment. NSP will disclose data on PHP's use of the High Voltage transmission system, with parties free to argue PHP's responsibility for associated costs. PHP is classified as an above-the-line customer in the 2026/2027 COS study, contingent on Board approval for a new tariff by 2026.

Responses to SBA Questions – 2 of 4 Question NS Power Response Please also refer to c) NS Power has indicated that when PHB is in operation minimum loads must be 15 MWs, yet the ELID tariff reflects 8 MW firm service. Since firm service is...

AI summary NS Power responds to SBA questions regarding PHP's firm load assumptions (8 MW vs. 15 MW), transmission cost allocations, and planning flexibility (65 MW). NS Power asserts PHP's load can operate at 8 MW absent biomass generator requirements and confirms 65 MW planning aligns with PHP's flexibility, referencing prior submissions and IRs.

Responses to SBA Questions – 4 of 4 Question NS Power Response Please also refer to Credits Questions a) The LIIR (Large Industrial Interruptible Rider) credit allocates the avoided capacity value based on forecasted non-coincident peak de...

AI summary NS Power responds to SBA questions regarding the LIIR credit and priority interruptibility. It explains that the LIIR credit is based on forecasted load and system peak, and that the value of the credit is established by the Settlement Agreement for 2026 and 2027. Regarding priority interruptibility, NS Power acknowledges the lack of comprehensive analysis but proposes retaining the 10% PI credit value as modelled in the GRA.

NON-CONFIDENTIAL 1 Request IR-20: 2 3 Reference: N-1, ELID Application, page 17. 4 5 6 In addition to [fixed cost recovery], the ELID tariff will affect fuel costs borne by other customer classes in two respects: 7 8 9 10 11 12 13 14 15 16...

AI summary The text discusses how the ELID tariff affects fuel costs for different customer classes, particularly focusing on the impact of DR service on PHP and ATL customers. It outlines scenarios where marginal costs are above or below average and explains how this affects cost distribution and the role of the FAM in addressing these effects.

4.2 REVENUE TO COST RATIO PHP's consultant states that NS Power's cost of service study calculates a revenue to cost ratio of 1.04373 or 4.373% greater than NS Power's cost to serve PHP and that when a regulator sets an R/C ratio above 1.0...

AI summary The document discusses NSP's revenue-to-cost (R/C) ratio of 1.04373, which exceeds NSP's cost to serve PHP, suggesting over-collection to subsidize other customer classes. NSP aligned PHP's R/C ratio with other classes (1.0438 for 2026, 1.0471 for 2027) as part of the ELID Tariff. InterGroup warns that altering the settlement agreement's terms could undermine its integrity and future settlements.

e Demand Control under the ELIADC Tariff and the Dispatchable Rider under the ELID Tariff are limited to changes to incorporate the provisions of dispatchable service and nomenclature.[25](#page-10-5) When questioned about the value that o...

AI summary The document discusses NSP's response to concerns about the ELID Dispatchable Rider, explaining that under the ELID Tariff, PHP customers fully cover fixed costs, benefiting all customers. However, the value from dispatching PHP load accrues solely to PHP, as their charges are embedded cost-based, aligning with ATL tariff principles.

Recommendation: The Board should consider reasonableness of the DR savings to be fully credited to PHP. Further, NSP states that consistent with the ELIADC Tariff, PHP operations under the DR will be governed by Operating Procedures develo...

AI summary The Board is urged to assess the reasonableness of DR savings credits to PHP. NSP argues Operating Procedures for PHP under DR should not require NSEB approval, as benefits/costs flow solely to PHP. However, stakeholders recommend Board approval to ensure transparency and protect other ATL customers from potential revisions favoring PHP.

p>40 NSP Response to Information Request Synapse-23. 41 NSP Response to Information Request IG-13. 42 NSP Response to Information Request Synapse-14. 43 See NSP Response to Information Request Synapse-14, Synapse-15, SBA-6. 44 NSP Response...

AI summary NSP proposes an Interruptible Rider with a Dispatchable Rider mechanism, increasing savings transferred to PHP from 25% to 100%. InterGroup argues this risks double-counting benefits for PHP, potentially disadvantaging other customers. NSP acknowledges PI service reduces interruption risks for other customers but has not quantified its value, prompting InterGroup to call for revisiting the PI credit in future proceedings.

Municipal Utility Rates Review For Town of Drumheller (AB) (2022): Developed a water and sewer utility rate model that allows systematic calculation of appropriate water and sewer utility rates to charge to ratepayers. Developed rate desig...

AI summary The document details various municipal utility rate reviews conducted between 2020 and 2025, focusing on developing fair rate structures, revenue requirements, and cost-of-service studies to ensure financial sustainability for water, sewer, and other utilities across multiple Canadian municipalities.

Economic/Financial Analysis For Northwest Territories Power Corporation (NTPC) (2009-Present): Develop business cases for NTPC's capital projects as part of regulatory requirements. The business cases include substantiation of a public nee...

AI summary The text details economic/financial analysis work for NTPC and QEC, including business case development for capital projects, regulatory approval support, and valuation assessments. It also covers economic forecasting for the City of Swift Current's utility rationalization efforts, focusing on cash flow, capital spending, and rate level scenarios.

For the Ontario Energy Board (2024) Study director for a review of cost award processes, consultant and legal fee tariffs and options for improving regulatory efficiency. Reviewed practices in a number of Canadian and American jurisdiction...

AI summary The text outlines consulting roles in regulatory reviews, including cost award processes, tariff improvements, and efficiency reforms for the Ontario Energy Board and other jurisdictions. It highlights work on revenue requirements, rate design, and cost-of-service analyses for various utilities and governments.

Approval of an Above-the-Line Tariff Applicable to Port Hawkesbury Paper (M12661) Bates White Evidence – Confidential Version - Customer Charge ($/month) : Designed to recover the "costs associated with the provision of dispatch service to...

AI summary NSPI proposes an Above-the-Line Tariff for Port Hawkesbury Paper (PHP), including monthly customer charges, demand charges based on peak demand, energy charges tied to load and Goose Harbour output, and Above-the-Line Rider charges. PHP may earn Dispatchable Rider Credits to offset costs. The proposal is part of NSPI's 2026-2027 General Rate Application.

Q. Please summarize your evidence with respect to NSPI's application. - A. Again, our evidence addresses only the Customer Charge, Energy Charge, Dispatchable Rider, - and treatment of Goose Harbour output. Regarding the Customer Charge, w...

AI summary The evidence recommends revising NSPI's proposed Customer Charge to $12,291.67/month with reconciliation for ELID Tariff costs, updating the COSS model for ELID Energy Charge accuracy, and rejecting the DR credit due to insufficient load-shifting safeguards. PHP's cost recovery and Goose Harbour output integration are emphasized.

- "conservative" choice. Rather, NSPI has selected the value from its range that is most likely to - under-collect the costs that the Customer Charge is intended to recover. - While it is a worthwhile endeavor to assign 100% of the ELID Ta...

AI summary NSPI acknowledges the challenges in accurately tracking and reporting ELID Tariff administration costs, particularly for PHP, which may hinder effective reconciliation of under-recoveries. NSPI plans to use General Rate Applications to review and reset the Customer Charge, but lacks detailed cost tracking for the ELID Tariff.

III. Assessment of the Energy Charge - Q. Please summarize the ELID Energy Charge proposed in NSPI's application. - A. NSPI proposes an Energy Charge of 9.977 ¢/kWh in 2026 and 11.240 ¢/kWh in 2027. 52 - Q. How were the Energy Charge rates...

AI summary NSPI proposes ELID Energy Charges of 9.977 ¢/kWh (2026) and 11.240 ¢/kWh (2027), calculated via a cost-of-service study (COSS) that treats PHP as an ATL customer. The rates incorporate fixed costs and net PHP load after subtracting Goose Harbour output (507 GWh), reducing PHP's modeled load to 304 GWh. This lowers PHP's total payments but increases per-kWh charges due to fixed cost allocation.

Q. What is the effect of PHP net load being too low in the COSS? - A. In most direct terms, if PHP's net load in 2027 subject to the Energy Charge is 121 GWh rather - than 304 GWh, a 60% reduction, the revenue from PHP to NSPI would be low...

AI summary A lower PHP net load in the COSS reduces NSPI's revenue by ~$21M (60% reduction) and increases ELID Energy Charge rates due to fixed costs not scaling with energy use. This risks under-contributing to system costs, shifting burdens to other FAM customers. NSPI's application uses an inflated PHP net load, leading to undervalued Energy Charge rates.

Q. Would the PHP Deferral account correct for the potential cost recovery distortions under

AI summary The question examines whether the PHP Deferral account would address cost recovery distortions in the context of Nova Scotia Power, Inc. (NSPI) and Port Hawkesbury Paper (PHP). It focuses on regulatory mechanisms for managing cost deferral and recovery under Nova Scotia's energy framework.

Q. What do you recommend with respect to the ELID Energy Charge? - A. We recommend that the Board does not approve the ELID Energy Charge as proposed. We - recommend that NSPI be required to update the COSS model to better reflect likely P...

AI summary The recommendation is to reject the ELID Energy Charge as proposed, emphasizing the need to update the COSS model with accurate PHP net load estimates, including Goose Harbour's 168 MW capacity output. Modifying other ELID tariff components without this update risks under-recovery of costs from PHP, increasing FAM customer risk.

IV. Assessment of the Dispatchable Rider Credit

AI summary The document section evaluates the Dispatchable Rider Credit, focusing on its implications for rate structures and cost recovery mechanisms within Nova Scotia's energy regulatory framework. Key considerations include alignment with existing programs and impacts on stakeholder interests.

- the value of the DR credit, NSPI will conduct an ex post production cost simulation model run to - determine the total system FAM costs using "actual system conditions that occurred throughout the year," - but assuming PHP would consume...

AI summary NSPI proposes a method to calculate the DR credit by comparing actual system costs with a scenario assuming high load factor consumption by PHP. The DR credit would be recovered from all above-the-line customers, but concerns are raised about the credit's accuracy as a proxy for marginal price signals.

Q. Does the DR credit have the potential to be material? - A. Yes. As noted above, and notwithstanding our commentary on the estimate, NSPI estimates that - the DR credit would have been $3.5 to $5.5 million in 2025. All FAM customers woul...

AI summary The DR credit is deemed material, with NSPI estimating it would reach $3.5–$5.5 million in 2025. All FAM customers would contribute, with payments accruing to PHP. The estimate's validity is noted but not contested.

Q. Does NSPI suggest that other FAM customers will be held harmless from PHP's decisions

AI summary The question asks whether NSPI proposes that other FAM customers will be protected from the impacts of PHP's decisions. It centers on potential cost implications for FAM customers related to PHP's actions within the regulatory proceeding.

Nova Scotia Energy Board In the Matter of Approval of an Above-the-Line Tariff Applicable to Port Hawkesbury Paper (M12661) Bates White Evidence – Confidential Version - 1 Given the potential for variable Goose Harbour generation to have s...

AI summary The evidence suggests that variable Goose Harbour generation could impact cost recovery for PHP and FAM customers. It recommends that NSPI evaluate cost recovery under the ELID tariff annually.

Component NS Power's proposed ELID Tariff PHP's Proposed Adjustments PHP's Core Revenue-to-Cost Ratio 1.04 1.00 Proposal Energy Sales Forecast Forecast provided by PHP for GRA Revised 2026 and 2027 energy sales forecasts PHP's Preferred Op...

AI summary The document compares NS Power's proposed ELID Tariff with PHP's adjustments, focusing on revenue-to-cost ratios, energy sales forecasts, demand charges, and interruptible credits. PHP proposes a lower revenue-to-cost ratio and revised energy sales forecasts, along with adjustments to demand charges and interruptible credits.

IV. DEMAND CHARGE AND INTERRUPTIBLE CREDIT on PHP's firm load level of 8 MW, with no interruptible credit? A. No. PHP's consultants, Mr. Fitzhenry and Mr. Gorman of Brubaker and Associates (BAI), argue that NS Power's ability to curtail PH...

AI summary The discussion revolves around the appropriate basis for calculating PHP's demand charge and interruptible credit. PHP argues that its interruptible load does not contribute to NS Power's generation and transmission costs, but NS Power counters that transmission costs are driven by both interruptible and firm load, and that PHP's proposal would shift costs to other customers. NS Power also argues that compensating PHP at the full marginal cost would overstate its benefit to other customers.

TESTIMONY AND COMMENTS Indiana Utility Regulatory Commission (Cause No. 46120): Direct Testimony of Melissa Whited addressing the appropriate return on equity for Northern Indiana Public Service Company in light of its high rates and recen...

AI summary Testimony and comments from Melissa Whited and others in various regulatory proceedings across different states and provinces, discussing topics such as return on equity, electrification rates, cost of service studies, and infrastructure cost recovery mechanisms. These testimonies were presented on behalf of various organizations and commissions.

Extra Large Industrial Active Demand Control (ELIADC) Tariff 2025 Annual Report (NSEB M12768) NSPI Responses to IG Information Requests 1 Request IR-1: 2 3 4 Reference: 2025 Annual Report, Exhibit N-1, p. 3/9, Table 1 5 (a) Please explain...

AI summary The document outlines a request and response related to the ELIADC Tariff 2025 Annual Report, focusing on the benefits reported for 2025 compared to initial forecasts and the factors influencing the ADC load shifting differential. The response references a 2019 tariff application and provides context on expected annual benefits.

P may also be able to offer interruptible demand to the system and be credited for that offering, similar to other interruptible customers. - Finally, should value be demonstrated, there may be a basis for PHP to accept that its demand int...

AI summary The ELID rate proposal introduces a new tariff structure for interruptible demand, differing from the existing ELIADC rate by allocating costs based on below-the-line (BTL) COS principles. This approach limits contributions to NSP's fixed costs while using higher-priced marginal power sources. PHP may receive priority for demand interruptions and additional compensation if value is demonstrated.

- NSP has estimated that the fully optimized credit could be up to $11 million per year, but is unable to - provide the calculation of this value.[18](#page 1-14) NSP estimates half of this may be reasonably achieved by PHP each - year, bu...

AI summary NSP proposes a Dispatchable Rider (DR) mechanism with PHP, estimating $11M annual savings but lacking detailed calculations. The DR's economic value requires NSP to have control over PHP's load during system stress. The recommendation emphasizes practical dispatch control for NSP during reserve margin periods, with concerns over 100% DR credit allocation to PHP.

4.0 ADDITIONAL PROPOSALS FROM THE EVIDENCE OF PHP - PHP has submitted their own proposals for the ELID tariff which vary from the structure and principles - espoused by NSP. - The basic outline of the ELID is accepted by PHP, but with the...

AI summary PHP proposes modifications to the ELID tariff structure, including updated load forecasts, revised peak load definitions, 100% cost-based rate recovery, and ancillary services credits. These differ from NSP's GRA-based proposals, focusing on tariff design, cost recovery, and load management adjustments.

BOWMAN ECONOMIC CONSULTING INC., WINNIPEG, MANITOBA 2020 – current – Principal Consultant Conduct consulting assignments as Principal Consultant of new economic consulting firm, focused on utility regulation. Member, Society of Depreciatio...

AI summary Bowman Economic Consulting Inc. provides regulatory consulting services to industrial energy users in Manitoba and Newfoundland, focusing on rate design, revenue requirement reviews, cost of service, and demand-side management initiatives. They assist with General Rate Applications, cost-of-service analyses, and represent clients in regulatory proceedings.

Utility Regulation Conducted research and analysis for regulatory and rate reviews of electric, gas and water utilities in eight Canadian provinces and territories and international. Prepared evidence and expert testimony for regulatory he...

AI summary The text outlines a firm's extensive experience in utility regulation, including rate reviews, regulatory hearings, and analysis for various utilities across Canada and internationally. It highlights expertise in cost of service, revenue requirements, depreciation, and rate design, as well as involvement in regulatory processes and resource planning.

Utility Proceeding Work Performed Before Client Year Oral Testimony NTPC Hay River Franchise Disposition Analysis, support preparation of regulatory principles, rate impacts NWT PUB NTPC 2024 Yes Nelson Hydro Generic Cost of Capital Review...

AI summary This table lists various utilities and their involvement in different regulatory proceedings, including the work performed, the regulatory body involved, the client, the year, and whether oral testimony was provided. It covers a range of matters such as rate applications, cost of capital reviews, and class cost allocation studies.

Request IR-3: - Reference: Testimony, Section V, Page 33, Lines 11–18. Bates White outlines an extreme but - plausible scenario where PHP's annual net load subject to the tariff rate drops to zero, meaning - the mill would pay no Energy Ch...

AI summary The document references a scenario where PHP's net load could drop to zero, leading to no Energy Charge and failure to cover embedded fixed costs. It asks Bates White if customer classes using no energy from NSP due to a sleeving arrangement should be exempt from NSP's embedded fixed energy costs.

Request IR-1: - Refer to Section II of Bates White Evidence, where Bates White recommends that NS Power set - the Customer Charge at the midpoint of its estimated range, or $12,291.67/month.[1](#page-1-0) Bates - White further recommends t...

AI summary Bates White recommends setting the Customer Charge at $12,291.67/month with reconciliation to ELID Tariff administration costs. Questions seek clarification on whether this creates symmetric cost recovery, how under-recovery would be handled, and if full reconciliation would shift costs to PHP if NS Power's tracking methodology is validated.

Response IR-1: - (a) Confirmed. - (b) Given our response to part (a), the first part of this IR is inapplicable. We have not conducted a review of the allocation of any under-recovered ELID Tariff administration costs. However, those costs...

AI summary NS Power confirms parts (a) and (c) of IR-1, stating that under-recovered ELID Tariff administration costs would be recovered from other customers, including FAM customers, but no review of allocation was conducted. The response references M12661, an application for an Above-the-Line Tariff, and cites Bates White Evidence.

Request IR-2: Refer to Section V of Bates White Evidence, where Bates White notes that PHP receives significant benefits from the treatment of Goose Harbour output as a direct reduction of its purchases of tariff energy under the ELID Tari...

AI summary Bates White raises concerns that treating Goose Harbour output as a direct reduction of PHP's tariff energy purchases under the ELID Tariff may distort cost allocation. The question seeks whether this necessitates robust design of ELID Tariff elements like the Customer Charge and Dispatchable Rider, along with verifiable true-up mechanisms for accurate cost recovery from PHP.

ce this a reduction of 57 26 MW, and Mr. Bowman's recommendation would be an increase of 55 MW, 27 the relative ratio of change should be comparable. Using 2027 numbers, 28 the impacts are as follows: 29 Under the 65 MW scenario, PHP's all...

AI summary The text discusses cost allocation impacts under different peak reduction scenarios for PHP, with a 57 MW reduction leading to a $9.4 million cost decrease. It also outlines recommendations related to demand response (DR) control and savings sharing, with the latter having a potential impact of up to $11 million.

30 Added peak demand to 120 MW: $9.4 million (may be less, pending NSP analysis) 1 multiple places, NSP indicates that effectively no PHP is load is typically 2 on the system at coincident peaks, as it will have already been curtailed 3 un...

AI summary The text discusses the impact of adjusting the peak demand and interruptible load valuation for PHP (Port Hawkesbury Paper) under NSP's (Nova Scotia Power) proposal. It highlights a potential overvaluation of PHP's interruptibility credit, with calculations showing varying monthly credits based on different demand levels, and recommends eliminating the priority interruptible credit due to its lack of system value.

IG Request IR-1: Reference: N-19, Evidence of InterGroup, p. 5/pdf p. 7. Preamble: In s. 4.1, Inclusion of Interruptible Load in 3CP Calculation InterGroup stated: In InterGroup's experience this is a common problem with "interruptible" lo...

AI summary InterGroup is asked to identify alternative cost allocation methods for interruptible loads in the ELID Tariff, explain their operation, and assess their impact on demand cost allocation. It is also asked whether it agrees with using PHP's expected CBL operating load and if any method aligns better with the principle that ATL customers should pay their proper share of embedded system costs.

And, in its Recommendations at p. 2/pdf p. 4: Recommendation 2: InterGroup recommends that the Board consider the reasonableness of the DR savings proposed to be credited to PHP. a) Please identify the specific factors or criteria that Int...

AI summary InterGroup recommends the Board assess the reasonableness of DR savings credited to PHP, considering ELIADC's ADC mechanism issues, benefit-sharing arrangements, and using VCC percentages as a proxy for credit sharing.

CA Response IR-3: a) In InterGroup's view, the following factors need to be considered in assessing the quantum of DR savings proposed to be credited to PHP: - NSP cost-of-service study (COSS) already reflects interruptible service credit...

AI summary InterGroup argues that NSP's proposed DR credit to PHP may misalign with load seasonality, lacks alignment with existing cost allocations, and would shift costs to other customers via FAM. The response highlights issues with modeled baseline load assumptions, exclusion of VCC in the ELID Tariff, and reliance on theoretical data.

CA Response IR-4: a) Yes. - b) InterGroup believes that the proper mechanism should be aligned with key regulatory rate principles, in particular: - Simplicity and understandability; - Freedom from controversies as to proper interpretation...

AI summary InterGroup supports aligning the IR credit mechanism with regulatory rate principles, emphasizes the need to separate interruptible and DR service loads, and approves IR credit for 2026-2027 based on the GRA Settlement Agreement. However, they oppose future IR credit without a mechanism to prevent double-counting DR and IR service values.

IG Request IR-5: - Reference: N-19, Evidence of InterGroup, p. 13/pdf p. 15. - NSP further confirmed that LIIR customers who are not held as Operating Reserve could be physically interrupted ahead of PHP despite PHP's priority status…. - N...

AI summary NSP confirms LIIR customers not held as Operating Reserve may be interrupted before PHP, despite PHP's priority status. NSP remains uncertain about the value of Priority Interruptible service and how associated costs should be recovered.

CA Response IR-3: a) The rationale for why an interruptible credit based on a utility's avoided marginal cost of capacity cannot or should not exceed an embedded cost-of-service demand charge in the case of NSP's PHP ATL Tariff application...

AI summary The response discusses the rationale for limiting interruptible credits to avoid exceeding embedded cost-of-service demand charges in NSP's PHP ATL Tariff application, citing fairness and cost recovery principles. It also notes uncertainty about whether capacity costs are functionalized as energy costs under NSP's cost-of-service study.

CA Response IR-5: a) No. InterGroup's evidence page 9 and 10 discusses NSP's response to NSEB-3 (Exhibit N-7), where NSP states: While on the ELIADC Tariff, 75 percent of the Active Demand Control (ADC) value was assigned to FAM. However,...

AI summary The response discusses the ELIADC and ELID tariff differences, focusing on how PHP's fixed cost contributions and DR credit impacts other customer classes. NSP explains that PHP can ignore DR price signals, but this results in increased costs for other customers. InterGroup raises concerns about fairness and cost causation.

And, at p. 12 line 24, and p. 13, lines 1-2: We do not agree that NSPI has made the "conservative" choice. Rather, NSPI has selected the value from its range that is most likely to under-collect the costs that the Customer Charge is intend...

AI summary The text presents questions challenging NSPI's Customer Charge estimation methodology, under-recovery implications, midpoint justification, and tracking mechanisms, involving Bates White and NSPI. It questions whether NSPI's approach under-covers costs and how adjustments would be handled.

Response IR-2: - (a) The Customer Charge cost estimate range put forth by NSPI has limited support. As we explain in our evidence, "NSPI's methodology for developing the [Customer Charge] estimate is not well explained in its Application,...

AI summary NSPI's proposed Customer Charge estimate lacks sufficient support, requiring additional evidence. If no evidence is filed, an alternative approach would increase the charge to $12,291.67/month with a reconciliation mechanism to recover ELID Tariff administration costs from PHP. Labor cost tracking for ELID Tariff administration is recommended for transparency.

And at p. 16, lines 10-13 and 15-16: Combining both the lower projected PHP gross load, and the higher expected output from Goose Harbour, the net PHP load incorporated in the COSS would more appropriately be 121 GWh rather than the 304 GW...

AI summary The text discusses a discrepancy in PHP's net load projections (121 GWh vs. 304 GWh) and its impact on NSPI's revenue, estimating a $21 million annual shortfall if Energy Charge rates are approved without correction. Questions are raised about Bates White's calculations, the accuracy of the Energy Charge rate, and funding sources for the shortfall.

o set the Energy Charge rate, a lower amount of system fixed costs would be recovered from PHP, and a larger amount of system fixed costs would be borne by FAM customers. - (c) See response to IR-4(b)

AI summary The Energy Charge rate allocation would recover fewer system fixed costs from PHP customers while shifting a larger share to FAM customers. This approach is referenced in a prior response (IR-4(b)).

Response IR-6: - (a) Yes. PHP's response to BW-IR-2 states: "The market for paper is somewhat seasonal with winter and summer months having generally less demand than spring and fall. PHP's energy demand corresponds to this seasonal varian...

AI summary PHP's energy demand is seasonal, contradicting NSPI's claim of levelized consumption. The DR Credit calculation is deemed inaccurate due to reliance on a flawed premise. Seasonal variance in paper market demand aligns with PHP's energy use patterns.

Request IR-10: Reference: N-20, Bates White Evidence, p. 27, lines 4-9. Our sixth concern is that the DR credit represents a zero-sum mechanism that, if incorrectly calculated, could harm other FAM customers. Any load "smoothing" exercise...

AI summary The concern is that the DR credit calculation could overestimate benefits, harming FAM customers due to incorrect assumptions about load smoothing and operational variations.

M12661 Date Filed: June 18, 2026 BW (IG) Page 21 of 28 1 (i) How could a true-up mechanism be designed to address 2 this scenario specifically? 3 (d) Does Bates White recommend that the true-up mechanism be scoped and 4 approved as part of...

AI summary The document discusses the design of a true-up mechanism to address cost recovery issues related to PHP under the ELID tariff. It highlights concerns about the PSA allowing PHP to 'bank' excess energy and avoid tariff charges, as well as issues with transmission losses not being properly accounted for.

- (ii) No. - (b) Yes. - (c) No. Allowing banking of Goose Harbour generation as an offset to non- - contemporaneous PHP load is not generally consistent with PHP covering the actual - cost to serve its load. M12661 Date Filed: June 18, 202...

AI summary The text discusses the inappropriateness of allowing banking of Goose Harbour generation as an offset for non-contemporaneous PHP load, citing concerns about cost recovery impacts on PHP and FAM customers. It references a recommendation for NSPI to evaluate cost recovery under the ELID tariff annually.

And: We also recommend NSPI explain the methodology for tracking the costs of administering the ELID Tariff and how NSPI plans to ensure that 100% of the costs incurred above in administering the ELID Tariff are paid by PHP, including thos...

AI summary The text requests NSPI to explain the methodology for tracking the costs of administering the ELID Tariff and how PHP will cover these costs. It also seeks Bates White's opinion on quarterly reporting, the relationship between annual evaluation and true-up mechanisms, and the sequencing of these mechanisms in case of over-generation. Additionally, it asks whether the Board should impose specific reporting obligations.

M12661 Date Filed: June 18, 2026 BW (IG) Page 27 of 28 1 NSPI; and (iii) annual reporting of actual Customer Charge administration 2 costs against the eight identified tasks? 3 (i) If Bates White does not support quarterly reporting for it...

AI summary The document discusses cost recovery mechanisms, including annual reporting of customer charge administration costs and the proposed true-up mechanism to address discrepancies identified in annual reviews. Bates White recommends annual assessment of cost recovery with quarterly reporting of metrics, and does not oppose specific reporting requirements.

M12661 Date Filed: June 18, 2026 BW (IG) Page 28 of 28

AI summary The document is a regulatory proceeding filing from June 18, 2026, with the matter number M12661. It is part of a proceeding involving Nova Scotia Power Inc. and includes references to various studies and programs such as the cost-of-service study and the Energy Load Integration Demonstration.

Issued at Halifax, Nova Scotia, this 22nd day of June 2026. 1 Request IR-1: 4 5 Instead, I recommend that the Board direct PHP and NS Power to negotiate an 6 alternative credit value that would induce PHP's participation, while ensuring th...

AI summary The text requests clarification on whether Ms. Whited's position supports negotiating an interruptible credit for PHP rather than using cost-of-service analysis, and asks for the rationale, regulatory principles, and consistency with cost causation and revenue requirements.

l ratepayers if the compensation rate is less than the full avoided cost, but sufficiently high enough to induce participation by those resources, while also accounting for changes in revenue impacts. (c) (i – iii) PHP would be charged for...

AI summary The text discusses compensation rates for PHP, suggesting they should be set below full avoided costs to induce participation while managing revenue impacts. It also proposes charging PHP based on embedded costs to maintain cost causation principles and reduce overall costs to ratepayers.

tribution) would reduce costs to all ratepayers relative to obtaining the capacity from the marginal generator. (d) It is appropriate to deviate from a credit at the level of the full avoided cost of

AI summary The text discusses the potential cost savings to all ratepayers if a certain approach is taken instead of relying on the marginal generator for capacity. It also mentions the appropriateness of deviating from a credit at the level of the full avoided cost.

- capacity in order to ensure that the credits provided to PHP provide net benefits to other customers. - (e) (i iv) "Induce participation" means a credit high enough that PHP is willing to take service on the tariff. The minimum compensat...

AI summary The text discusses the determination of interruptible credit levels for PHP, emphasizing the need to balance participation incentives with ratepayer benefits. It highlights that the minimum compensation required to induce participation is higher than $8.404/kVA but lower than PHP's proposed $13.107/kVA. The discussion also considers industry practices and the importance of maximizing net benefits to all ratepayers.

Reply Evidence of Colin T. Fitzhenry and Michael P. Gorman 1 Q PLEASE STATE YOUR NAMES AND BUSINESS ADDRESS. 7 8 9 PHP is proposing a firm demand of 8 MW which reflects the demand  required by PHP at times of system transmission and gener...

AI summary PHP is proposing a firm demand of 8 MW and an interruptible demand, with the latter requiring credit at NS Power's avoided marginal cost of capacity. They also propose a Revenue-to-Cost (R/C) Ratio of 1.0 to ensure they pay only their cost to serve, avoiding subsidizing other customer classes.

Q DO YOU AGREE WITH INTERGROUP THAT ALLOWING PHP TO EARN AN IR CREDIT THAT EXCEEDS EMBEDDED DEMAND CHARGES WOULD CREATE A "NEGATIVE CONTRIBUTION" AND A DESIGN ERROR? A No. InterGroup's argument in PHP-IR-3(a) rests on the claim that becaus...

AI summary The response argues against the claim that allowing PHP to earn an IR credit exceeding embedded demand charges would create a negative contribution or design error. It explains that NS Power's tariff is based on embedded cost, not marginal cost, and that the COSS model does not fully classify generation capacity costs into demand charges. The response emphasizes that PHP's energy charge supports the system and that the IR credit should reflect the full avoided marginal cost of capacity.

Q DO YOU AGREE WITH MS. WHITED'S RECOMMENDATION TO ADJUST THE PHP IR CREDIT TO ACCOUNT FOR PHP'S REVENUE CONTRIBUTION FOR NEW CAPACITY? A No. While I agree with this recommendation in principle, I do not recommend adjusting the methodology...

AI summary The respondent agrees with the principle of adjusting the PHP IR credit to account for revenue contribution from new capacity but does not recommend changing the methodology at this time, citing negligible impact and potential non-uniformity. PHP is willing to collaborate on revisiting the calculation in a future proceeding.

TO PHP? A No. As discussed in PHP's direct evidence, a minimal transmission cost allocation is entirely appropriate based on cost-causation principles and system planning realities. System reliability studies, such as Steady-State Power Fl...

AI summary PHP's demand should be allocated based on its 8 MW firm demand, as it does not require incremental transmission investments and its interruptible load does not necessitate capacity expansion. Charging PHP for unused assets would unfairly burden the ELID class.

V. RESPONSE TO BOARD STAFF WITNESS BATES WHITE Q CAN YOU BRIEFLY SUMMARIZE THE RECOMMENDATIONS OF BATES WHITE? A Bates White recommends that several key components of Nova Scotia Power's proposed ELID Tariff be rejected or substantially mo...

AI summary Bates White recommends rejecting or modifying several components of Nova Scotia Power's proposed ELID Tariff, including the ELID Energy Charge, DR credit framework, and mechanisms in the Power Sales Agreement, to prevent cost-shifting and under-recovery risks. They suggest recalculating the ELID Energy Charge using an updated COSS model and implementing an annual true-up mechanism for cost recovery.

Q DOES NS POWER AGREE WITH BATES WHITE THAT THE ELID ENERGY CHARGES IS NOT BASED ON PHP'S COST OF SERVICE? A. No. In Bates White IR-7(a), NS Power was asked if it considers the ELID Tariff as offering PHP a discounted rate for power relati...

AI summary NS Power disagrees with Bates White's assertion that the ELID Energy Charges are not based on PHP's Cost of Service. NS Power confirms that the energy and demand charges in the ELID Tariff are based on the Cost of Service Study, but the interruptible demand and priority interruption credits for PHP are not cost-based, leading to a $4.2 million annual impact.

Q WHAT IS YOUR UNDERSTANDING OF BATES WHITE'S RECOMMENDATION TO ADJUST THE ELID ENERGY CHARGE USING A NET LOAD THAT WOULD BE 121 GWH? A Bates White's recommendation to alter the COSS model inputs to force a higher per-unit Energy Charge ra...

AI summary Bates White's recommendation to adjust the ELID Energy Charge using a 121 GWh net load is rejected due to contradictory methodology. Bates White admits the net load framework is inappropriate for determining actual cost to serve PHP load, making the recommendation unreasonable.

Q. Why is the P90 generally utilized in respect of wind power projects? A. The P90 level of wind production is used as a standard for financial calculations. This level is crucial for lenders to ensure that the project can service its debt...

AI summary The P90 level is used in wind power projects to ensure lenders can confidently size loans based on conservative production estimates. The discussion also addresses the use of P50 versus P90 in cost-of-service studies and the need to update models to reflect actual net load from wind facilities.

PHP's equipment, and for this reason PHP is only willing to take the risk related to being dispatchable in exchange for a corresponding benefit that has the monetary value to compensate for this risk. Finally, Bates White expresses a conce...

AI summary PHP argues that its load is predictable and that the DR credit is based on an incorrect premise. It contends that it pays all costs regardless of energy use, and that other industrial consumers also have variable loads without similar compensation concerns.

Evidence of Melissa Whited (Synapse Energy Economics), on behalf of Counsel to Nova Scotia Energy Board, page 3, lines 15-17. May 8, 2026. 1 costing and billing. This approach is unique to the ELID Tariff but appropriate for a tariff for w...

AI summary The evidence discusses the ELID Tariff's approach to costing and billing, which dynamically optimizes customer load and eliminates forecast variance. It also addresses concerns about energy assumptions and proposed ELID Tariff Energy Charge, with BW opposing the application due to high PHP energy amounts assumed.

ruptible service.[19](#page-11-3) This is the long-established process applicable to ATL interruptible service in Nova Scotia. DATE FILED: July 8, 2026 Page 12 of 25 As provided in NS Power's responses to Synapse IR-14 and SBA IR-2 part (c...

AI summary The document discusses the long-established process for ATL interruptible service in Nova Scotia, referencing historical approvals and methodologies for determining interruptible credit amounts. It also mentions system cost savings associated with interruptible service and how they are credited and assigned across rate classes.

e result is (absent the SA provision), the calculated ELID Tariff IR credit is much larger than the calculated LIIR IR credit. While Synapse recommends a larger IR credit should be provided to PHP than the SA prescribes, Synapse is of the...

AI summary The document discusses the calculation of ELID Tariff IR credits and LIIR IR credits, noting that the ELID Tariff IR credit is significantly larger than the LIIR IR credit. Synapse argues against providing the full calculated credit to PHP, citing concerns about over-allocation of benefits and shifting costs to other customers.

pan id="page-14-1"> InterGroup Evidence (CA Consultant), page 7. Refer to NS Power's responses to CA IR-1 and CA IR-9. Synapse Evidence (BCC), page 13, lines 16-18. allocate all of the benefits of avoided capacity to PHP, leaving other cus...

AI summary The text discusses NS Power's position on the allocation of benefits from avoided capacity, emphasizing that the ELID IR credit is established by the SA and that cost recovery practices are cost-neutral. It also mentions the proposed ELID Tariff and the distinction between interruptible service and DR service. The revenue-to-cost ratios for 2026 and 2027 are noted as an integral consideration in the SA.

levels of precision on the ELID Tariff. Power systems and customer markets and loads are dynamic and assumptions imperfect. The shift to the embedded cost construct will reduce the variability in cost Bates White Evidence (BCC), page 19, l...

AI summary The document discusses the ELID Tariff and its assumptions, noting that while it may not be perfect, it offers benefits to all customers by ensuring that incremental costs during high load periods are borne by PHP rather than others. It also highlights the shift to an embedded cost construct for improved transparency and simplicity.

3.0 CONCLUSION It is encouraging that the evidence submitted in this proceeding is focused primarily on tariff costing and pricing parameters and, in general, seems to accept the new above-the-line ELID Tariff construct. In this regard, Sy...

AI summary The proceeding concludes that NS Power's proposed ELID Tariff is generally reasonable but requires modifications to address capacity costs and benefit allocation. The ELID Tariff is seen as a positive evolution in service to Port Hawkesbury Paper, though challenges related to its complexity and prior bankruptcies of the pulp and paper operation at Point Tupper are noted.

to M12661, Exhibit N-1, the Application submitted by NS Power, Section 3.1 Consistency with Established Rate-making Practice in Nova Scotia, starting on page 15 of 19, and please answer the following: 1. Confirm if the components listed as...

AI summary The text outlines several requests related to NS Power's application, focusing on the ELID Tariff and its components, including the Customer Charge, Interruptible Rider credit, and DR credit. It asks for definitions, calculation methods, and comparisons of credits under different mechanisms, as well as clarification on cost inclusion and reporting practices.

Request IR-5: Refer to M12661, Exhibit N-2, Evidence of Colin T. Fitzhenry and Michael G. Gorman on behalf of PHP, page 18, lines 5-23 and page 19, lines 1-6. specifically, the use of three coincident peak ("3-CP") and cost-causation princ...

AI summary Request IR-5 asks for clarification on the use of NARUC Manual guidance related to interruptible capacity allocation, cost-causation principles, and penalty mechanisms for non-performance by PHP. It also requests a statistical method for a 3-CP allocator and an explanation of why historical peak contributions are inappropriate.

ed by NS Power is not appropriate. 8. If 65MWs reflects the historical reliance of interruptibility (including suppressed meter readings), why is this not an appropriate allocation? Request IR-6: Refer to M12661, Exhibit N-2, Evidence of C...

AI summary The text contains several requests for information related to the Dispatchable Rider (DR) and interruptible credit, including questions about the allocation of capacity, the appropriateness of the DR component, and the valuation of capacity. These requests are part of a regulatory proceeding and involve NS Power and PHP.

22 Request IR-2: 23 24 (a) Please provide COSS and resulting tariff reflecting all parameters proposed by PHP in its 25 evidence, including: 26 27 i. designing the capacity charge to reflect PHP's actual 8 MW firm demand rather 28 than the...

AI summary The request asks for updated cost-of-service (COSS) and tariff calculations based on PHP's proposed parameters, including adjustments to capacity charges, interruptible credit, revenue-to-cost ratios, and forecast energy requirements for 2026 and 2027. It also requests updated rates for all customer classes and supporting calculations.

42 Request IR-6: 43 In their evidence, Brubaker & Associates state: 44 45 The interruption demand service will not impose resource capacity cost on NS Power 46 because this demand will be served only on an as-available basis. Hence, NS Pow...

AI summary Brubaker & Associates argue that interruptible demand does not require a capacity charge as it is served on an as-available basis. They suggest that NS Power can recover associated costs through the ELID energy charge. The request asks for an updated ELID tariff design and COSS reflecting this approach.

ctice for pricing of the interruptible credit? 2. Please explain why PHP’s interruptible credit should differ from the LIIR Tariff (excluding the priority interruptibility premium)? Request IR-2: 1. Please provide COSS and resulting tariff...

AI summary The text outlines several requests related to the pricing of interruptible credit, tariff design, and cost-of-service models for PHP, including adjustments to capacity charges, revenue-to-cost ratios, and implications for deferral account balances. These requests are part of a regulatory proceeding involving Nova Scotia Power Inc.

d. This interruptible credit should be priced at NS Power’s estimated marginal cost of capacity of $13.107/KVA, and updated in the next GRA filing to reflect the current cost of capacity. (N-2 page 3) Please confirm that other than the int...

AI summary The document discusses the pricing of an interruptible credit for NS Power, the ELID tariff design, and cost recovery for interruptible demand. It also requests clarification on tariff design, cost allocation differences, and NSPI’s plans if PHP does not accept the ELID tariff post-2026.

M12661 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act , R.S.N.S. 1989, c. 380 as amended -and- IN THE MATTER OF: AN APPLICATION by NOVA SCOTIA POWER INCORPORATED for approval of an Extra Large Industrial Dispatchable A...

AI summary The Consumer Advocate has requested information regarding the ELID tariff for Port Hawkesbury Paper, including claims by Brubaker & Associates that interruptible demand will not require capacity charges and will be recovered through the ELID energy charge.

Request IR-2: 10 11 Reference: Evidence of Colin T. Fitzhenry and Michael P. Gorman (BAI), page 19. 12 13 14 15 NS Power provided an updated COSS for 2026 and 2027 based on a reduction in PHP's total demand coincident with the winter syste...

AI summary NS Power has provided an updated COSS for 2026 and 2027, showing a significant reduction in PHP's winter system peak demand, which would result in a rate reduction of approximately $6.5 million in 2026 and $9.4 million in 2027.

Request: 1920 21 22 18 Please confirm, or explain otherwise, that the reduction in cost allocation to PHP created by the reduction in PHP demand from 65 MW to 8 MW by service area as apportioned to PHP in the 2026 and 2027 Cost of Service...

AI summary The document requests confirmation or explanation regarding the reallocation of cost reductions from PHP due to decreased demand, as reflected in the 2026 and 2027 Cost of Service Studies, to other above-the-line rate classes.

M12661 – NS Power Application for Approval of the ELID Tariff NSPI Information Requests to PHP 1 2 3 site, that includes approximately 4MW that are needed to maintain the shared services required for the NS Power Port Hawkesbury Biomass Pl...

AI summary NS Power is seeking approval for the ELID Tariff, which includes an energy charge designed to recover both fuel and non-fuel costs of service. The ELID will not require an interruptible credit for NS Power's interruptible power supply above PHP's firm demand of 8 MW. BAI is requesting confirmation on the understanding of the cost-of-service methodology and rate design.

INFORMATION REQUESTS To: Port Hawkesbury Paper James MacDuff 1300 – 1969 Upper Water Street Purdy's Wharf, Tower II P.O. Box 730 Halifax, NS B3J 2V1 By email: [[email protected]](mailto:[email protected]) Tel: 9...

AI summary The document is an information request from Synapse Energy Economics, Inc. to Port Hawkesbury Paper, seeking clarifications and supporting references related to cost of service, PHP treatment, and tariff-related matters. The request includes specific page and line references from submitted documents and testimony.

- a. Please provide NS Power's most recently filed cost of service study in Excel with working formulas. - b. Please provide the allocators associated with each cost category in NS Power's most recent cost of service study along with a bri...

AI summary The document requests detailed information from NS Power regarding their cost of service study, including allocators, derivation of allocators, stakeholder input, and modifications to cost allocation methods. It also asks for an explanation of the LIIR credit amounts for 2026 and 2027, along with associated workpapers.

g whether a tariff is treated as ATL or BTL. 3. Regarding allocation of costs to PHP in NS Power’s cost of service study: 1. Please provide NS Power’s most recently filed cost of service study in Excel with working formulas. 2. Please prov...

AI summary The document requests detailed information on cost allocation methods, tariff structures, and stakeholder input related to NS Power's cost of service study and the Large Industrial Interruptible Rider (LIIR), including formulas, allocators, derivation processes, and feedback received.

Question: (a) Please confirm that these proposed energy charges do not include any costs associated with the securitization deferral account as proposed in the GRA. (b) Please provide a calculation of the proposed securitization rider appl...

AI summary The question asks about the inclusion of securitization deferral account costs in proposed energy charges, a calculation of the securitization rider for 2026 and 2027, and the impact on demand and energy charges if securitization is not approved. It also references a lower interruptible credit for PHP compared to the company's established practice.

Questions: (a) Please confirm that NS Power simply used the credit applicable to Large Industrial Interruptible customers as the credit to be applied to PHP's interruptible load on the basis that this was the language of section c) of the...

AI summary The document contains several questions directed at NS Power regarding the application of interruptible credits to PHP's load, cost causation, and the inclusion of an interest component in the credit payable to PHP under the Dispatchable Rider. Issues include the use of the Large Industrial Interruptible credit, cost of service treatment, and the approval of the ELID Tariff.

21 Request IR-3: 22 Reference: N-1, ELID Application, page 5. As proposed, rather than relying solely on PHP metered data at the time of the 3CPs, the setting of the PHP coincident peaks for costing and pricing purposes will require judgme...

AI summary The document requests an explanation of the methodology used to determine the 65 MW figure as the PHP 3CP billing determinant, including data, calculations, assumptions, and judgments made in the process.

Consistent with the foregoing, it is proposed that the assumed costing/billing demand also be adopted and applied for billing purposes throughout the year (i.e. the PHP 3CP figure employed for Tariff costing and pricing would also be appli...

AI summary The text proposes adopting a fixed demand charge based on the PHP 3CP figure for billing purposes, similar to how it is used in tariff costing. It raises questions about other customer classes billed on fixed demand charges, the appropriateness of this approach, and requests a framework for setting or resetting the PHP 3CP demand determinant.

- 3 Preamble: NSPI indicates the cost-of-service information is contained in files - 4 associated with M12451, General Rate Application, specifically SR-01 and associated - 5 Attachments. - 6 Please provide either a copy of the Cost-of-Ser...

AI summary The document requests the provision of cost-of-service information related to M12451, specifically regarding different load scenarios for PHP, including firm and interruptible loads, and associated pricing proposals from NSPI and PHP.

16 Request IR-10: 17 Reference: N-1, ELID Application, Page 8, lines 11-17. As noted in the SA, for 2026 and 2027, the proposed interruptible credit applicable to PHP is the same as proposed for the LIIR: $7.638 per kVA and $7.667 per kVA...

AI summary The document discusses the proposed interruptible credit for PHP under the ELID application, noting that the current proposed rate is significantly lower than the company's established practice. The request asks for confirmation of the credit using the established approach and the anticipated cost variance for 2026 and 2027.

5 Reference: N-1, ELID Application, page 9 – Priority Interruptible Credit. - 6 (a) Please provide all workpapers, calculations, and analysis supporting the 7 value of $0.764/kVA and $0.767/kVA as the priority interruptible credit, and 8 s...

AI summary The text requests detailed explanations and supporting documentation for the calculation of the priority interruptible credit values ($0.764/kVA and $0.767/kVA), specifically how the 10% premium over the standard interruptible credit was derived. It also inquires whether the credit is based on actual incremental avoided costs or is a policy decision, and asks for historical context on its application.

at times, conflict with optimal load dispatch. Based on experience with the ELIADC Tariff, the Company estimates that the actual benefit that can be realized will be approximately half this amount. - 12 (a) Please elaborate on the sentence...

AI summary The text requests detailed explanations and data regarding the ELIADC Tariff, including operational examples, cost-of-service study data, and modeling for future years. It also asks how high load factors and SEA amounts are considered in calculations related to PHP and NSPI.

1 Request IR-27: 2 Reference: N-1, ELID Application, Attachment 1, ELID Tariff, page 8 of 8. - 3 Annually, NS Power shall report to the Board to confirm the dollar value of 4 system savings that have been achieved through the dispatch of t...

AI summary NS Power is required to annually report system savings achieved through the dispatch of the Customer's load under the Operating Procedure to the Board. The Customer is entitled to a credit based on the cost differential between actual and calculated system costs if served under the high load factor scenario.

the Operating Procedures? Reference: N-1, ELID Application, page 17. In addition to [fixed cost recovery], the ELID tariff will affect fuel costs borne by other customer classes in two respects: 1. DR service will reduce total system costs...

AI summary The ELID tariff will impact fuel costs for other customer classes, particularly through DR service and incremental costs for serving PHP. The GRA includes DR benefits in the fuel budget but lacks compensation for PHP, which will be addressed via the FAM. The excerpt outlines the relationship between marginal and average fuel costs but does not fully explain how DR credit interacts with these variations.

tomer will be entitled to a credit equal to the cost differential between the actual annual system cost and the calculated system cost if the Customer was served under the high load factor scenario. 1. Please compare the reporting provided...

AI summary The text discusses the ELIADC and ELID tariff structures, focusing on reporting requirements, fixed cost revenues for PHP, and the need to update tariffs based on revised energy sales forecasts. It also raises questions about transparency, audit mechanisms, and cost recovery.

y sales forecasts for PHP” and suggests that “[a]ligning the tariff with current usage assumptions ensures that energy cost allocations and revenues accurately reflect PHP’s actual cost of service." 1. Please indicate whether NSPI agrees w...

AI summary The text discusses the alignment of tariff assumptions with current usage for PHP, requests NSPI's agreement and impact analysis, and asks for updated historical 3CPs and line loss considerations. It also addresses the outdated avoided peaker cost used in determining monthly credits for interruptible load.

Reference: N-1, ELID Application, page 3. Preamble: NSPI’s Application states that "[t]he Tariff costing and billing parameters are applied as noted in the Settlement Agreement (SA) which underpins the Company's 2026-2027 General Rate Appl...

AI summary The document discusses the consistency of the ELID Tariff with the Settlement Agreement (M12451), the reasonableness of estimated system savings from PHP's load dispatch, and the recommended R/C ratio for ELID. It includes questions for PHP and BAI on these topics.

- Refer to Section II of Bates White Evidence, where Bates White recommends that NS Power set the Customer Charge at the midpoint of its estimated range, or $12,291.67/month.[1](#page-1-0) Bates White further recommends that the Customer C...

AI summary The text requests clarification on Bates White's recommendation regarding the Customer Charge and its reconciliation with the actual costs of administering the ELID Tariff. It asks whether the recommendation is symmetric, and if not, why under-collection is not addressed similarly. It also inquires about the treatment of under-recovery and who would bear those costs.

Request IR-2: Refer to Section V of Bates White Evidence, where Bates White notes that PHP receives significant benefits from the treatment of Goose Harbour output as a direct reduction of its purchases of tariff energy under the ELID Tari...

AI summary The document discusses concerns raised by Bates White regarding the treatment of Goose Harbour output under the ELID Tariff and its impact on PHP's cost allocation. It questions whether this affects the need for robust and verifiable elements of the ELID Tariff, including the Customer Charge and Dispatchable Rider, and whether true-up mechanisms are in place for accurate cost recovery.

27 1 2 (b) What factors does Ms. Whited believe make a transition appropriate or not appropriate? 13 14 15 16 17 18 19 A. No, for two reasons If PHP were compensated at the full marginal cost without accounting for this avoided contributio...

AI summary Ms. Whited argues that compensating PHP at full marginal cost without accounting for avoided contributions would over-allocate benefits to PHP and shift costs to other customers. The question also asks whether the theoretical net-avoided-cost figure should be used as an upper bound for negotiations and if it can be calculated using NSPI's capacity cost data.

33 that PHP was already contributing to some fixed cost recovery via the VCC 1 in the context of the ELID Tariff; and (ii) whether it would produce a demand 2 cost allocation to PHP that is higher or lower than the 65 MW approach 3 adopted...

AI summary The text discusses the cost allocation to PHP under the ELID Tariff, referencing the Variable Capital Charge (VCC) in the ELIADC Tariff and its role in fixed cost recovery. It also questions whether alternative methods of cost allocation, based on PHP's expected load, are consistent with principles of proper cost allocation for ATL customers.

- 3 Preamble: Throughout this section, Bates White assesses the Customer Charge - 4 Methodology and the Risk of Under-Recovery. At p. 12, lines 10-22, the evidence states: NSPI did not use a bottom-up methodology (using assumed labour hour...

AI summary Bates White evaluates the methodology used by NSPI in estimating the Customer Charge, noting that NSPI did not use a bottom-up approach or historical data. The analysis suggests that NSPI's choice may lead to under-recovery of costs intended to be collected through the Customer Charge.

NSPI has made the "conservative" choice. Rather, NSPI 11 has selected the value from its range that is most likely to under-collect the 12 costs that the Customer Charge is intended to recover. - 13 (a) Does Bates White agree that, without...

AI summary NSPI has selected a conservative estimate for the Customer Charge, potentially under-recovering costs. Bates White is questioned on the validity of NSPI's methodology, the implications of under-recovery, the reasoning behind their midpoint recommendation, and whether their proposed credit mechanism is reciprocal for over-recovery.

2 Reference: N-20, Bates White Evidence, p. 35, lines 15-17 and p. 36, lines 1-3, 3 Recommendations: Given the potential for variable Goose Harbour generation to have significant effects on cost recovery — to the potential disadvantage of...

AI summary The text recommends that NSPI evaluate cost recovery under the ELID tariff annually and explain the methodology for tracking and ensuring that all administration costs of the ELID Tariff are paid by PHP. This is due to the potential impact of variable Goose Harbour generation on cost recovery for PHP and FAM customers.

osal, would the expected revenue contribution be based on the percentage of PHP's contribution to NSP's planning reserve margin in relation to the total system planning reserve margin? Please explain. (e) Considering that NSP's Application...

AI summary The text discusses the pricing of interruptible credits for large industrial customers, specifically whether the credit should be based on full marginal cost or adjusted to ensure other customers share benefits. It references NSP's established practices and considerations of system costs and avoided capacity.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT and IN THE MATTER OF: An Application by Nova Scotia Power Inc. ("NS Power") for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff applicable to Port...

AI summary The Nova Scotia Energy Board is considering an application by Nova Scotia Power Inc. for an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. The Consumer Advocate (InterGroup Consultants) has been asked to respond to several questions regarding settlement agreements, load modeling, and the calculation of interruptible credits and demand charges.

5, Evidence of P. Bowman, pages 13-14, Recommendation 4. [ 13 ](#page-2-17) N-38, NSPI Reply Evidence, page 23, lines 15-19. July 16, 2026 Page 4 Crystal Henwood confidentially), a new methodology to quantify the value of the ADC mechanism...

AI summary The document discusses the introduction of a new methodology to quantify the value of the ADC mechanism, developed in line with the 2022–2023 FAM Audit. This new approach raises concerns about the evidentiary foundation for the DR credit and its implications for ratepayers, as it was introduced after the Information Request process, limiting opportunities for meaningful examination.

3. The Complexity and Novelty of the Proposed Tariff Require an Oral Hearing Bowman's evidence notes that the proposed ELID rate is "complicated and unusual in utility rate regulation" and that "[n]o comparable rate could be identified in...

AI summary The proposed ELID rate is described as complex and unusual in utility regulation, with no comparable rate in Canada. It combines multiple mechanisms, including an above-the-line cost-of-service framework and production cost simulation, raising concerns about cost recovery and potential financial consequences for ratepayers. The Industrial Group argues for an oral hearing due to the novelty and complexity of the tariff.